GRI Content Index Service

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1 GRI Content Index Service Methodology GRI (year)

2 Introduction The GRI G4 Sustainability Reporting Guidelines have increased user-friendliness and accessibility. The emphasis on what is material encourages organizations to provide only information that is important to their business and stakeholders. This allows organizations and report users to concentrate on the sustainability impacts that matter, resulting in reports that are more strategic, more focused, more credible, and easier for stakeholders to navigate. As in G3 and G3.1, the Content Index in the G4-based sustainability report is the central navigation tool that is often used as the first point of reference for report users when looking for certain GRI Disclosures and those Aspects that have been identified as material. The GRI Content Index should be included in all GRI reports, whether they are published as PDFs, paper-based reports or online. In all reports, the GRI Content Index should be placed prominently to allow GRI report users to quickly find the information that they are looking for. To help reporters to improve the accuracy and usability of the GRI Content Index and ensure that this is aligned with the requirements of GRI disclosure G4-32, GRI has designed a new service, the GRI Content Index Service ("the Service"). This new service aims to initiate a dialogue between GRI and reporting organizations before reports are published, to emphasize the role of the Content Index as a navigation tool in the report and promote the value of reported data by making it easy for report readers to find. 1. Scope of the Content Index Service The GRI Content Index Service aims to help improve the transparency and usability of GRI reports. It focuses on General Standard Disclosure G4-32 from the GRI G4 Sustainability Reporting Guidelines and verifies that the GRI Content Index of the report is accurate. Under the GRI Content Index Service, GRI will verify that all GRI G4 disclosures in the report can be found where indicated in the GRI Content Index and are clearly indicated by disclosure labels 1 (for example, G4-32, G4-DMA or G4-LA12 ). The actual content of the report will not be reviewed. Verifying the quality of the reported information and the process of preparing the disclosures is beyond the scope of the Service. Verifying the location of sector-specific and non-gri disclosures is beyond the scope of the service. 2. Application requirements When requesting the Service, the following documents must be submitted to GRI by to Completed Sign-up form (Draft) report, including a GRI Content Index, disclosure labels and assurance statement, if applicable (for details see Sections 2.2. and 2.3. and 2.4 below) 1 See section Steps of service, Step 5 for explanation of disclosure labels. Page 2 of 10

3 Once it has received all the required documentation in good order, GRI will provide written confirmation by that the Service has been initiated and will indicate the expected date for providing the first feedback. a. Sign-up form The Sign-up form can be downloaded from the GRI website. By submitting a completed Signup form, the Reporting Organization, or if applicable the third party on behalf of the Reporting Organization, confirms that it agrees with these terms and conditions for the Service. b. Content index The Content Index must be prepared in line with General Standard Disclosure G4-32. Additional information can be added as long as it does not confuse readers or obscure the functionality or contents of the Content Index. There should be a placeholder for the GRI Content Index Service Icon 2, which will be placed on the first page of the Content Index in the report. GRI recommends that the GRI Content Index Tool, available for free download on GRI s website, is used when preparing the Content Index. c. (Draft) report Organizations are required to submit final or near final versions of the relevant report, in which it is clearly indicated which In accordance option (Core or Comprehensive) has been chosen. The report must include the above-mentioned version of the Content Index with placeholder for the GRI Content Index Service Icon. If relevant, (draft) external assurance statement must be included in the report. d. Disclosure labels In the (draft) report, all GRI disclosures must be clearly distinguished using disclosure labels. Use of disclosure labels is not required by the G4 Guidelines for reports to be In accordance, but it is obligatory for the GRI Content Index Service. Disclosure labels (for example, G4-13, G4-E4 or G4-DMA ) help report readers to locate the information that they are looking for and help to give reporting organizations more control over the transparency and integrity of their sustainability data. GRI uses the disclosure labels to verify that the locations of disclosures as referenced in the Content Index are accurate. See Section 3. Steps in the service, Step 5 for more details about disclosure labels. 3. Steps in the Service The GRI Content Index Service focuses on General Standard Disclosure G4-32 from the GRI G4 Sustainability Reporting Guidelines and verifies the accuracy of the GRI Content Index through the following steps: Step 1: Is the relevant information correctly included in the Content Index? Step 2: Are the references provided in the Content Index clear? 2 See Section 5. Content Index Icon for more details about the GRI Content Index Service icon. Page 3 of 10

4 Step 3: Where applicable, are the reasons for omission provided in line with the G4 Guidelines? Step 4: Is indication of external assurance included for each reported disclosure? Step 5: Are the indicated locations of disclosures accurate? Is the relevant information correctly included in the Content Index? According to Disclosure G4-32 from the GRI G4 Sustainability Reporting Guidelines, reporters should complete and publish the full Content Index as presented in G4 for the respective In accordance option: Core or Comprehensive. This means reporters cannot leave out any parts of the Content Index such as, for example, the column on assurance or rows for Disclosures on Management Approach for any Material Aspect. It is also not possible to merge information from several columns into one. Core In accordance option Do not include the instruction text in grey in the above image in the Content Index of the Report. General Standard Disclosures G4-1, G4-3 to G4-34 and G4-56 are required and should therefore be included in the Content Index. Do not include the instruction text in grey in the above image in the Content Index of the Report. Page 4 of 10

5 For all the selected material GRI Aspects, the Disclosure on Management Approach (DMA) and at least one related Indicator should be included in the Content Index. Comprehensive In accordance option Do not include the instruction text in grey in the above image in the Content Index of the Report. General Standard Disclosures G4-1 to G4-58 are required and should therefore be included in the Content Index. Do not include the instruction text in grey in the above image in the Content Index of the Report. For all the selected material GRI Aspects, the Disclosure on Management Approach and all the related Indicators should be included in the Content Index. It is possible to add the name of the Indicator next to the number of the Indicator. Additional items, such as extra columns to indicate compliance with other frameworks, may be added as long as they do not confuse readers or obscure the functionality or contents of the G4 Content Index. If additional rows of non-g4 related disclosures are added to the list of GRI disclosures, this should be distinct in layout or in any other way be clearly identifiable as non-gri Aspects. These do not fall within the scope of the GRI Content Index Service. Each row of the Content Index table should provide coherent and consistent information. See disclosure G4-32 and FAQs about G4 Guidelines for more guidance. Page 5 of 10

6 Are the references provided in the Content Index clear? References provided in the Content Index should be specific (for example, a general reference to the annual report to shareholders would not be acceptable, unless it includes the name of the section, table, etc.) and refer to information that is publicly available and readily accessible. Information related to Standard Disclosures required by the In accordance options may already be included in other reports prepared by the organization, such as its annual report to shareholders or other regulatory or voluntary reports. In these circumstances, the organization may elect not to repeat those disclosures in its sustainability report and instead add a reference to where the relevant information can be found, as long as the above-mentioned requirements are met. Both electronic or web-based reporting and paper reports are appropriate media for reporting. Organizations may choose to use a combination of web- and paper-based reports or use only one medium. At least one medium (web or paper) should provide users with access to the complete set of information for the reporting period as listed in the GRI Content Index. While the reporting organization may in some cases choose to include the reported information directly in the Index instead of providing a reference to where the information can be found in the report, it is important to keep in mind that too much text in the Content Index can diminish its clarity and navigational functionality. See G4 section Reporting Required Standard Disclosures by Using References and FAQs about G4 Guidelines for more guidance. Page 6 of 10

7 Where applicable, are the reasons for omission provided in line with the G4 Guidelines? This step only applies to cases when reasons for omission are provided. Reasons for omission may apply for certain Standard Disclosures in exceptional cases. The Reporting Organization should recognize, however, that omitting a large number of Standard Disclosures may invalidate its ability to claim that its sustainability report has been prepared In accordance with either the Core or Comprehensive option of the Guidelines. Reasons for omission are applicable only when it is not possible to disclose certain required information. In such cases there should be a clear indication of the following: 1) the information that has been omitted; 2) the reason for omission and explanation as recognized by the G4 Guidelines that should further include the following as relevant: a) Not applicable a reason why it is considered to be not applicable should be disclosed b) Confidentiality constraints constraints are to be disclosed c) Legal prohibitions reference to the specific legal prohibitions should be made d) Currently unavailable disclose the steps being taken to obtain the data and the expected timeframe for doing so. See G4 section Reasons for Omission and FAQs about G4 Guidelines for more guidance. Is indication of external assurance included for each reported disclosure? GRI recommends the use of external assurance for sustainability reports in addition to any internal resources, but this is not a requirement to be In accordance with G4 (see Disclosure G4-33). External assurance may refer to activities designed to result in published conclusions about systems or processes, activities designed to assess or validate the quality or level of performance of an organization, such as issuing performance certifications, or compliance assessments. External assurance should be conducted by competent groups or individuals external to the organization who follow professional standards for assurance, or who apply systematic, Page 7 of 10

8 documented, and evidence-based processes ( assurance providers ). Overall, for external assurance of reports using the G4 Guidelines, it is important that the assurance providers: are independent from the organization and therefore able to reach and publish an objective and impartial opinion or conclusions about the report; are demonstrably competent in both the subject matter and assurance practices; apply quality control procedures to the assurance engagement; conduct the engagement in a manner that is systematic, documented, evidence-based, and characterized by defined procedures; assess whether the report provides a reasonable and balanced presentation of performance, taking into consideration the veracity of data in the report as well as the overall selection of content; assess the extent to which the report preparer has applied the Guidelines in the course of reaching its conclusions; and issue a written report that is publicly available and includes an opinion or set of conclusions, a description of the responsibilities of the report preparer and the assurance provider, and a summary of the work performed to explain the nature of the assurance conveyed by the assurance report. For each reported G4 disclosure, the Content Index should include an indication of the following: 1) whether or not the relevant disclosure has been externally assured; and 2) if yes, the page number where the relevant External Assurance statement can be found. Are the indicated locations of disclosures accurate? All reports submitted for the GRI Content Index Service should include disclosure labels to identify the location of the GRI disclosures as indicated in the GRI Content Index. The disclosure labels can be incorporated in the report in different ways: for example, include the disclosure labels directly in the text, as footnotes, in subscript or superscript next to chapter or subchapter titles, or incorporate the labels in the layout solutions. Below are some visual examples. Page 8 of 10

9 Locations of the disclosures referenced in the Content Index should be easily found, accurate and reflect the references provided in the GRI Content Index. If a disclosure is explained over a range of pages (no more than 2-3), the disclosure label should be used on all pages. 4. GRI feedback GRI will provide its first feedback within 8 working days of receipt of the documents required for the GRI Content Index Service. Should Reporting Organization require the first feedback within less days, it is possible to request the first feedback within 4 full working days after the receipt of the required documents. This involves additional fee (see Terms and Conditions for more details). This feedback will be presented in a table format and will include recommendations for each of the five steps, if applicable. The second (and subsequent) feedback will take the same format as the first feedback (table to be sent by ), and will highlight those points that still require improvement after the second submission of the amended documents. Should Reporting Organization require the second (and subsequent) feedback within less days, it is possible to request the second (and subsequent) feedback within 2 full working days after the receipt of updated documents. This involves additional fee (see Terms and Conditions for more details). Page 9 of 10

10 5. GRI Content Index Service icon When GRI s recommendations have been correctly implemented in accordance with section 4. above, GRI will provide the Reporting Organization with the GRI Content Index Service Icon, which must be included on the first page of the GRI Content Index in the final version of the Report. The icon must be used as provided by GRI changes are not permitted. This includes, but is not limited to, changes in the color, proportion, or design of the icon, or removal of any words or trademark symbols. In addition, the icon may not be animated, morphed, or otherwise distorted in perspective or appearance. Use of the icon in other locations in the report, on a website or other communications is not permitted. GRI will keep a copy of the latest version of the (draft) report and the Content Index submitted by the Reporting Organization. If, after GRI has issued the GRI Content Index Service Icon, the Reporting Organization makes any changes to the GRI Content Index or location of the disclosure labels which are within the scope of the Service, the Reporting Organization must remove the icon from the Report immediately. In such cases, all references to the Service in the report and other communications that the Reporting Organization provides or has provided must be removed immediately. Page 10 of 10

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