The first report to follow the new GRI G4 guidelines is welcome, but lacks a winner’s traits

Announced with great fanfare and heralded widely as the world’s “first GRI G4 report”, the City of Warsaw’s integrated sustainability report 2013 may strive to honour the spirit of the Global Reporting Guidelines, but it falls way short of best-practice G4 adherence.

Issued as a 13-page, minimally formatted document, the report both over-reaches in its claims and under-delivers in its execution. The rush to assume the mantle of “first” seems to have usurped the care needed to fulfil the intent of the guidelines. This haste relegates the city’s report to more of a curiosity rather than a true model for others to follow.

The report adopts a line-by-line ticking-off of GRI G4 indicators, in tremendously abbreviated fashion. In fact, a reader perusing the cover page’s environmental, economic/financial and societal highlights would hardly need to leaf through the rest of the document. Other than the major messages, there are no real stories or in-depth narratives to speak of. Bullet-pointed facts and data leave readers to draw their own inferences about the context around the city’s performance.

Materiality discussion…? 

Given the G4’s core requirement that reporters disclose information of highest priority, a reader would expect to find a robust discussion of the city’s materiality analysis. In Warsaw’s report, this central defining feature is reduced to a pat statement that gives readers no insights into the city’s materiality assessment process or consideration of related GRI reporting principles. Instead, three bullet points briefly note that the city evaluated stakeholder concerns, that data was “placed into the context of sustainability”, and that the report reflects significant impacts. All of these points are a starting assumption for any G4 report, not actual disclosure.

Without a deeper dive, the city is not accountable for the quality or depth of its assessment, the process is opaque and non-comparable to other reports, and stakeholders are left in the dark about whether their views were truly considered.

Also disappointing is the city’s apparent disregard of guidance material provided in the (admittedly exhaustive) G4 implementation manual. Although this guidance could be considered optional, to simply cast it aside entirely negates its purpose and benefits. The G4 manual seeks to be comprehensive with good reason – to reflect the insights and inputs of the global multi-stakeholder deliberations of the past few years, and to offer a roadmap for what constitutes comprehensive and useful disclosure.

Warsaw further disregards many required indicator sub-points. For example, gender-based breakdowns are omitted, the precautionary principle is acknowledged perfunctorily with no explanation of process or application; and although stakeholders are listed, the key topics noted are not ascribed to any particular stakeholder groups.

Disclosures on management approach (DMAs) suffer the same fate. Under G4, reporters are expected to provide DMAs for material topics (“aspects”), including an accounting of impacts, management approach, and evaluation process. Warsaw instead provides vague declarations and generic statements. The “umbrella” DMA for occupational health and safety, collective bargaining, security and anti-corruption is all of two sentences long, and tells readers that workers are allowed to unionise, health and safety programmes are in place, and a code of ethics that includes anti-corruption provisions is communicated to employees – an entirely insufficient response.

Finally, Warsaw’s claim of producing an “integrated” report, by sole virtue of incorporating a modicum of financial metrics, is questionable at best. Any GRI-based report that responds to indicator EC1 can make the same assertion, and does not an integrated report make. With multiple resources readily available, including the International Integrated Reporting Council’s draft framework, the city should contemplate a more robust discussion of strategic integration, capital flows, civic model, and other substantive indications of financial and sustainability integration.

Despite its drawbacks, the City’s motives for publishing this report seem sincere. Warsaw is hosting the November 2013 COP 19 United Nations Climate Change Conference, and through its demonstration of attention to sustainability, can impress conference goers and citizens alike. Warsaw is also stepping into uncharted waters – many municipalities are still struggling to define what sustainability means, let alone gathering and publishing data.

A section titled “disclaimers” offers perhaps the most transparent view into the city’s motivations, citing its report as a “pragmatic exercise in measuring and communicating progress … not in service of any party or elected official”. Viewed through this lens, the city’s good-faith effort to use world-class guidance for its reporting does signal leadership. Given the iterative nature of reporting, Warsaw will have ample opportunity to hew more closely to the G4 in coming years.

Snapshot

Follows GRI?             Claims to follow GRI G4 at the “core in accordance” level.

Assurance?                  No

Materiality analysis?   Alluded to, but no process description or visualisation included.

Goals?                         Very limited.

Targets?                       For energy consumption and greenhouse gas emissions only.

Stakeholder input?      References to stakeholder engagement, but no descriptions of actual input.

Seeks feedback?         Includes contact names and emails.

Key strength:              Demonstration that GRI G4 guidelines can be used outside of the corporate sphere.

Chief weakness:          Inadequate and fragmented adherence to G4 disclosure requirements.

Pleasant surprise:         Focus on biodiversity within city limits.

Level of integration:   1 (on a scale of 1 to 5, where 5 is “fully integrated”).

Aleksandra Dobkowski-Joy is a principal at Framework LLC.

City of Warsaw  CR Reporting  Poland  sustainability report