Next year will be the 20th anniversary of the first release of the Global
Reporting Initiative’s
(GRI) Guidelines for
sustainability reporting, now referred to as the GRI
Standards — an important milestone
for what has become the world’s leading international standard for non-financial
reporting.
It wasn’t until 2002, however, that reporting principles per se were included
by GRI in the second generation of its Guidelines (G2) that year. In total,
there were eleven such principles listed, four of which are now separately
broken out as Reporting Principles for Defining Content in the current version
of the Standards.
One of these four principles is Sustainability
Context,
which essentially calls for organizations to report their performance “in the
larger context of ecological, social, or other limits or constraints.” As
explained to me privately by Allen
White,
one of the founders of GRI and creator of the Sustainability Context
principle, “I argued that absent context, even if all enterprises continuously
improve performance, the collectivity may violate boundaries that define a
thriving, regenerative world.”
Notwithstanding the truth of this, G2 provided no guidance on how to actually
apply the Sustainability Context principle, nor has it done so in the versions
that followed. Even so, the current edition of the Standards faithfully
includes the principle, still expressed in language that closely mirrors the
phrasing used in 2002:
“… the aim is to present the organization’s performance in relation to broader concepts of sustainability. This involves examining its performance in the context of the limits and demands placed on economic, environmental or social resources, at the sectoral, local, regional, or global level.” (GRI, 2016)
Because of the absence of guidelines for how to specifically implement the
Sustainability Context principle, it is quite possibly the case that no GRI
report has ever included it. And yet without it, as White also said to me,
“Sustainability measurement and reporting … is simply not sustainability
measurement and reporting” at all. True enough, but there’s more.
Houston, we have a problem
As if the complete absence of context in mainstream sustainability reporting
weren’t bad enough, that’s only the half of it. It’s true that sustainability
reports without context hardly qualify as sustainability reports at all — and
that the emperor, therefore, has no clothes — but it is also true that all other
aspects of accounting must, too, be defined before, not after, meaningful
reporting can occur. Missing guidelines for context is just the tip of the
iceberg.
Indeed, how else are reporters supposed to know how to measure things, so that
performance can be correctly reported, if not by reference to accounting
standards? First, we measure; then, we report. Thus, by implication, reporting
standards should logically follow accounting standards, not precede them. But
when the GRI and other reporting standards were created, no such accounting
standards existed, nor do they today — a perfect recipe for arbitrary,
capricious and even downright misleading reporting.
And that, unfortunately, is exactly what has been happening for the past
nineteen years, now going on twenty. We blithely skipped over the critical and
indispensable step of figuring out how best to perform sustainability
accounting, and instead jumped headlong into reporting as if measurement was a
settled matter — it was not! The result? Nineteen-plus years of corporate
sustainability reporting that tells us nothing about the sustainability of
organizations, thanks mainly to the fact that no one took the time to first
determine how best to measure it.
Imagine what things would be like if we carried on that way in financial
reporting — there would be hell to pay for sure. While far from perfect, at
least we have something today called Generally Accepted Accounting Principles
(GAAP),
which provides everyone with codified standards for how best to measure the
financial performance of organizations before any of them try to report it.
First, we perform standards-based measurement; then, we perform standards-based
reporting. What a concept!
In 1933, shortly after the great depression and long after principles for
double-entry bookkeeping had been developed, the Security Act of
1933 was enacted by the
U.S. Congress (also known as the Truth in Securities Act, incidentally), by
which it became mandatory for all publicly traded companies to prepare and
release financial
statements. Such a step
would not have been possible had standards for financial accounting not already
existed. Today, such financial statements routinely include income statements,
balance sheets, statements of changes in equity, and cash flow statements — all
according to GAAP, a standard for accounting.
Where, then, is the equivalent of GAAP in sustainability or TBL accounting?
Missing in action, is where. And because of that, GRI and every other
sustainability-related performance reporting standard in place today
(GRI,
<IR>, SASB, etc.)
are developmentally premature, genetically hobbled, so to speak, by the absence
of their evolutionary progenitor, sustainability or TBL accounting.
And how could it be otherwise? A solution for such accounting hasn’t been born
yet. Or has it? Could it be, instead, that it has been born and that the
makers of reporting standards have simply not noticed it yet?
Putting the horse back in front
Having now seen that in sustainability reporting we have been collectively
guilty of putting the cart before the horse — reporting before accounting — let
us now agree that the time has come to turn things around and put the horse
before the cart. It is time, that is, to settle in on some basic principles for
how best to make sustainability accounting, and the reporting that follows,
context-based. Indeed, to its everlasting credit — and with a special tip of
the hat to Allen White — the one thing we should all feel comfortable in saying
is that in G2, GRI definitely got the Sustainability Context thing right. That
is clearly the regulative ideal we should be subscribing to!
Listen to how White put it, as he reminisced on the evolution of the principle
in the run-up to G2: “In the course of wide-ranging stakeholder consultations,
it became clear that true sustainability reporting at the enterprise level must
be contextualized within boundaries that define the ecological, social and
economic systems limits, both upper and lower, ceilings and floors.”
There can be little doubt that this is true and that Sustainability Context
must absolutely underlie sustainability accounting in order for the TBL
performance of an organization to be understood. For if under any other
principle it is possible for organizations to score “sustainably”, and yet still
be operating in ways that put the quality or sufficiency of vital resources or
the well-being of those who depend on them at risk, then there is something
terribly wrong with the accounting system in use.
In the shadow of all of this in the past several years has been the development
of what I and many others refer to as Context-Based Sustainability
(CBS) — a
market-driven, open-source framework of guidelines for how best to
operationalize the Sustainability Context principle in not just reporting, but
measurement as well — all in an effort to flesh out the horse and put it back in
front of the cart where it belongs.
In addition to having garnered support from the United
Nations
(for use by all organizations), B Lab (which has
endorsed use of
the MultiCapital
Scorecard
by Benefit Corporations), Reporting
3.0 (for all organizations), and many others, CBS is now
taking the stage as the centerpiece of a new Certified Triple Bottom Line (TBL)
certification
program
still very much in its formative
stages
at the non-profit Social Accountability International
(SAI). Perhaps best known for its long-standing
SA8000®
certification for human rights in the workplace, SAI has been administering
CSR-related certifications to organizations around the world for more than
twenty years now, much longer than anyone else.
To be clear, standards for financial reporting were preceded by standards for
financial accounting by literally hundreds of years (since at least 1494 by
Luca Pacioli). Standards for
financial accounting, that is, came long before standards for financial
reporting were even considered — just as it should be. The same logic applies to
sustainability accounting, or for what we can more broadly think of as TBL
accounting.
But is the stage sufficiently set for that? Has the scholarship in Triple Bottom
Line accounting been around long enough; evolved long enough; been vetted and
continually improved enough, to warrant a jump from theory to codified
standards? Are we really ready to make that move?
Absolutely, yes, is the answer. As I have explained here
before,
principles and practices for how best to do TBL accounting first started to
appear in the management literature some three hundred years ago in the work of
Hans Carl von
Carlowitz, and not only
in the more recent writings of John Elkington in
1994 and others.
Context-based thinking, too, has been percolating in economics for at least a
century, if only in the form of the
literature
on multiple capital
accounting
or what I and others call
multicapitalism.
Make no mistake, then: The timing is right for this — for taking concrete steps
to standardize a set of generally accepted TBL accounting principles, and for
making GRI and other reporting standards stronger than they’ve ever been before.
Indeed, this idea doesn't replace them; it fortifies and enhances them. And none
too soon, mind you. By the GRI timeline alone, we are at least nineteen years
late and the clock is still ticking. So, let’s get on with this. Go, SAI!
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Mark W. McElroy, Ph.D. is the founder and Executive Director of the Center for Sustainable Organizations and the original developer of the Context-Based Sustainability method.
Published Nov 13, 2019 1pm EST / 10am PST / 6pm GMT / 7pm CET