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Although Pressure-State-Response (PSR) and Driver-Pressure-State-Impact Response (DPSIR) frameworks guide the conduct of many SoE reporting exercises, there is a need to modernise SoER through the use of new tools and frameworks. For example: Much could be gained through the use of a standardised set of disclosures along the lines of the GRI Standards for Sustainability Reporting. The identification of materially significant issues for reporting through a more comprehensive stakeholder engagement process, would likely bring a greater sense of urgency to topics that require immediate attention. Too often there is little or no emphasis on the government’s management approach to issues and their disclosure and the relationship between governance, strategy, risk and target setting. In addition, there is an opportunity to identify and pursue relevant Sustainable Development Goals.

Expressions of interest for a webinar on the Future of State of the Environment Reporting are sought here. If you are interested, please send an email to Dr Robert Gale at:



15 December 2020: Submission to the UNDP public consultation process


The public consultation process of the UNDP initiative to develop "SDG Impact Standards for Entreprises" closed 15 December 2020. The UNDP's SDG Impact Team will now be considering all the feedback as they actively refine and improve the Standards. I was able to find a little time to contribute the following points and quearies about the initiative, including the need for it and how it has been developed.

1) The recent KPMG (2020) survey reports that the Global Reporting Initiative (GRI)/Global Sustainability Standards Board (GSSB) is by far the most successful sustainability reporting framework. Yet, the GRI Principles are not referred to (although the UNGC Principles are central), and the GRI Management Approach and disclosures are not discussed in any substantive way. This overall point is raised because the SDG Impact Standards for Enterprises, which claims not to be another sustainability reporting standard, fails to provide a sufficient rationale for an independent exercise on practice indicators, rather than a joint exercise with GRI/GSSB and/or a broader coalition of externality reporting frameworks.

2) It is also puzzling that earlier work on the SDG Compass is omitted, along with other GRI-SDG linkages. What are the shortcomings of the Compass and other omitted documents for the purposes of practice indicators? Note that GRI now has a Certified Sustainability Professional designation which includes a training module on how to integrate the SDGs into the GRI sustainability reporting process.

3) Practice indicators which are largely backward looking will not be sufficiently informative to guide decisions. The State of Corporate Sustainability Reporting ought to obligate corporates to document material conditions and trends and to be specific about projected trends and target setting. The term ‘trend’ is not mentioned once in the document. This point is raised to tackle the flipside of long-term value creation which is not corporate value destruction, but the systematic sliding into further ‘ecocide’ – which is surely the overarching concern of performance-based externality reporting even if not overtly stated. The UN Secretary General’s call this past week for all countries to declare a Climate Emergency has captured the sense of urgency that needs to be communicated in SDGs and practice indicators, but I see little evidence of urgency in these sometimes very general indicators.

4) Moreover, the foundational elements of the Standards clearly mention human rights but omit planetary boundaries, which is hard to comprehend. Something on scientific based targets is required. Companies find all sorts of ways to be obtuse about the four standards proposed: Strategy, Management Approach, Transparency, and Governance. Unambiguous statements, however, are required. I recommend adding the category of performance Trends as its own standard so that practice indicators within this Standard speak to real outcomes over time, or lack thereof. Practice indicators need to demonstrate to investors and other stakeholders how corporates are turning things around from a sustainable development perspective.

5) I’d recommend dropping the term “trade-off’ which economists think of an objective calculation of costs and benefits easily determined by a monetary CBA method. In discussion of value creation, we are more likely dealing with “choices” between values, and the materiality of impacts on people and planet. For the most part we need to make sustainability choices not unsustainable trade-offs.

I appreciate the opportunity to provide some feedback, albeit short of time to be more comprehensive.

Regards, Robert Gale

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The @UNDP public consultation process to develop #SDG Impact Standards for Enterprises" closed 15 December 2020. Some of my reservations are published at:

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