The Report of the GRI G4 Public Comments Process WorkshopCaux Round Table Japan jointly hosted the...

Caux Round Table- Japan 29-33-505, Sakuragaoka-cho, Shibuya-ku, Tokyo, 150-0031

TEL: 81-3-5728-6365 FAX: 81-3-5728-6366 Website: http://www.crt-japan.jp

1

The Report of the GRI G4 Public Comments Process Workshop

August 23rd

, 2012

Caux Round Table Japan



2

The Report of the GRI G4 Public Comments Process Workshop

August 23rd, 2012


Caux Round Table Japan jointly hosted the GRI G4 Public Comment Workshop in

Tokyo with the Global Reporting Initiative (GRI) on Thursday August 23. The

workshop was conducted by Marjolein Baghuis, Director of Communications &

Network Relations, Global Reporting Initiative.

This workshop included an interactive session per change area where more than fifty

Japanese participants (CSR corporate, professionals, academics and members of

NPOs and NGOs) presented their concerns and recommendations for the G4 public

comment period according to the G4 exposure draft.

・Description

1. Date: August 23rd, 2012 10:00～17:00

2. Place: Kwansei Gakuin University Tokyo Marunouchi Campus

3. Host: Caux Round Table Japan,

Global Reporting Initiative, GRI

Support: BRAIN CENTER INC., Cetus & General Press Inc.,

Toppan Printing Company,

4. Participants: 45 Organizations, Total 52 participants

Details Corporation 29 companies 29 participants

Government Officials 2 Government agencies 7 participants

CSR Experts & NGOs 6 Organizations 6 participants

Consultant 4 companies 6 participants

CSR Publishing 4 companies 4 participants

*See the Appendix 1 for more details

The comments are not representative of the company, only individual input in the workshop



3

Discussion Summary

1. Governance

According to the discussion groups, two different kind of issues were addressed: the

first one regarded the guidance itself and the other concerned challenges that

Japanese companies will have to consider alongside their own governance structure.

Regardless the disclosure items (social-environmental, transparency and governance

system), disclosure itself should be more focused on certain limited but necessary

items that facilitate clear judgement in order to respond to stakeholders’ real

expectations and requirements, due to an underlying concern over "the cost benefit

for the information users”.

The consultation process between the stakeholders and the Board of Directors and

the relationship with other Directors are important forms of information which are to be

covered across different governance systems.

The disclosure standard should be prepared with a clear and simple necessary

procedure, including specific directions, such as "what actions should be taken" or

"what information should be disclosed". The items to be disclosed should be more

selectively chosen and within a simplified structure.

The regional implications should also be a factor to focus on when developing

transparency policies according to these guidelines as in Japan there is a sort of

unique structure of corporate governance which generates certain resistance.

In Japan, currently, the majority of corporate managers are reluctant to disclose

information beyond that which is mandated as their legal obligation and also the

governance of this process is considered one of their weaknesses. However,

regardless of the expected challenges for the Japanese companies, it is expected that

the "how- related governance items will better reflect the "essence" of the companies.

Governance systems in Japan in general have a middle-up rather than a top-down

style. There may be variables between the governance elements in different countries,

which do not fit with the single unified model. The items of the disclosure should be

able to capture such unique strength.

2. Disclosure on management approach

The first consensus regarding the purpose of generating a CSR report confirmed that



4

the GRI guidelines are a useful tool for learning about the CSR activities from the

leading global companies and for undertaking CSR initiatives at one's own

companies/organizations.

For the disclosure of the management approach, corporate philosophies, such as

"Kyosei" (living and working together for the common good), cherished by many

Japanese companies, embrace the essence and drivers for the company as they

engage in CSR activities or implement CSR management. Therefore, it is significantly

important for the companies to state their corporate values (basic premises) in their

reports, and these will presumably reflect the sustaining value.

Other aspects of management were addressed such as the time frame for reporting

sustainability and enabling comparability. However, with 10-, 20- and 30- year time

scales, management policies on these issues may inevitably tend to be conceptual

and abstract. Also, within a given limited timeline, it is clearer to understand how risks

and challenges will be addressed and how activities will be managed.

Usually management focus is risk driven, which means that the higher the risk, the

stronger the management focus. Calculating the risk probability, the management will

find it easier to address certain issues of social interest.

3. Supply Chain

Even though there were many specific comments on the final report, we may

summarize the following aspects:

There are some areas which overlap and are not easy to comprehend; on that matter,

it is recommended to define classifications based on categories, because there are a

huge variety of relationships with suppliers which have to be taken into consideration.

Situations change depending on power relationships between suppliers and

customers. Location is also an important issue to be considered when within the

global value chain and it is nearly impossible to match the place for production, the

place of consumption and the place of procurement.

Competitiveness is also an important aspect to consider in terms of disclosure of the

supply chain. Firstly, there are many indicators which are questionable in terms of

how they can improve the corporate value, social value and suppliers’ value. And

secondly, supply chain management impacts on the competitive advantage of the

company. Since the information related to procurement is critical, especially for the

quality and cost competitiveness of manufacturers, there is a resistance to this kind of

disclosure.



5

Based on what is mentioned above, it is expected that the G4 indicators generate

win-win-win situations for the three elements: corporate value, social value and

suppliers’ value since the supply chain is the key for the strategy of the company.

4. Boundary

The value chain mapping suggested as an earlier step, prior to the conventional step

of selecting materiality, is a huge advancement on the guidelines, but the method and

scope of mapping are issues we need to address and understand if it will require

public comments or stakeholders dialogue in order to identify relevant aspects.

As the method of mapping should be identified, the relationship between the terms

"Aspects", "Materiality" and "Topics" should be clearly mapped-out based on precise

definitions. There should be no room for interpretation, while at the same time some

liberty in mapping should be acceptable, rather than restricting this process (since

many indicators and complicated contents are already involved).

How far the scope of the mapping should extend is subject to change according to the

different industries and business. Therefore, there should be some specific directions

or indicators given in the Sector Supplement for the use of defining the boundary.

The mapping can be positioned as a pre-task for ISO26000 due diligence. Though G4

does not mention ISO26000, clear distinction between GRI as a reporting guideline

and ISO26000 as action may be helpful and, since there are many companies

engaged in ISO26000, the importance of mapping at this point will be effectively

communicated.

Unexpected impacts to the business operation may need to be considered in the

boundary. It may be needed not to only consider the boundary related to business, but

also socio-environmental impacts and world affairs.

5. Application Level

In terms of public relations it is really interesting, but the new "in accordance with"

statement might be difficult to comply with in terms of a strong commitment that

companies might not be capable to undertake.

In Japan, only a few companies have conducted application level checks

appropriately, which implies that this does not make a significant difference. Instead, it

is important to improve the status of GRI and position it as a reporting guideline

harmonized with other guidelines.



6

There is a concern that greater emphasis on materiality and integrated reporting may

be resulting in lower levels of information disclosure, despite the fact many companies

have been successfully improving their disclosure levels by utilizing the scheme of the

application level.

The reason for discontinuing the application level is the misunderstanding that some

companies utilize the application level to assess their performance level, and this

should be pointed out and corrected. Based on the general Japanese experience, the

step by step approach for improving disclosure and activity levels based on fixed

criteria and standards is effective.


Executive Director

Hiroshi Ishida



7

Program

10：00 Opening Remarks

10：10 Overview of the GRI G4 PCP Workshop’s purpose

Hiroshi Ishida, Executive Director, Caux Round Table Japan.

10：30 Introduction of G4 PCP and Discussion

Marjolein Baghuis, Director, Communications & Network Relations,

Global Reporting Initiative

11：30 Tea break

12：00 Group Discussion, part 1

・Group leader

Governance Group：Toshinume Yamaguchi, Caux Round Table Japan

Disclosure on Management Approach Group

：Mizue Unno, So-Tech Consulting Inc.

Supply Chain Group：Kaori Kuroda, CSO Network Japan

Boundary Group：Hiro Motoki, E-Square Inc.

Application Level Group：Yoshihiko Yamabuki, Cetus & General Press Inc.

13：00 Lunch

14：00 Group Discussion, part 2

・Group Leader

Governance Group：Yoshihiko Yamabuki, Cetus & General Press Inc.

Disclosure on Management Approach Group

：Takao Hiraishi, BRAIN CENTER INC.

Supply Chain Group：Keiichi Ushijima, Hitachi, Ltd.

Boundary Group：Ayako Sonoda,Cre-en incorporated

Application Level Group：Masaki Wada, BURBERRY JAPAN K.K.

15：00 Tea break

15：30 Wrap-up

16：30 Closing Remarks

Hiroshi Ishida, Executive Director, Caux Round Table Japan.

17：00 Workshop Close



8

A．Group Discussion

Group Discussion was divided into 5 groups and took place twice; Governance, Disclosure on

Management Approach, Supply Chain, Boundary, Application Level）

Here is the list of the leaders of each group’s discussion.

A-1．Governance

Part 1 Group Leader: Toshinume Yamaguchi, Caux Round Table Japan P9

Part 2 Group Leader : Yoshihiko Yamabuki, Cetus & General Press Inc. P10

A-2．Disclosure on Management Approach, DMA

Part 1 Group Leader: Mizue Unno, So-Tech Consulting Inc. P11

Part 2 Group Leader : Takao Hiraishi, BRAIN CENTER INC. P13

A-3．Supply Chain

Part 1 Group Leader: Kaori Kuroda, CSO Network Japan P14

Part 2 Group Leader : Keiichi Ushijima, Hitachi, Ltd. P15

A-4．Boundary

Part 1 Group Leader: Hiro Motoki, E-Square Inc. P17

Part 2 Group Leader : Ayako Sonoda,Cre-en incorporated P19

A-5．Application Level

Part 1 Group Leader: Yoshihiko Yamabuki, Cetus & General Press Inc. P21

Part 2 Group Leader : Masaki Wada, BURBERRY JAPAN K.K. P23



9

A-1. Governance

1st

Discussion Group Leader: Caux Round Table Japan Toshimune Yamaguchi

1. Overview

Based on the following two considerations (a) and (b), the group discussion focused on

three issues 2, 3, and 4.

a. It is not clear what is expected to be found by the disclosure of Governance &

Remuneration information.

b. Disclosed items should be simpler and clear in terms of their disclosure purpose.

2. Information Disclosure

There seems to be an extremely large number of items to be disclosed, and it is

questionable if stakeholders expect and require to see them all. Based on the

understanding that the purpose of the disclosure is to facilitate judgment of whether or not

managers have misbehaved and/or whether conflicts of interest of shareholders and

employees are properly prevented by systems in place, the disclosure should be more

focused on limited but necessary items that facilitate clear judgment.

3. Social Environmental Involvement

We understand and support the idea that the next revision of the standards will further

focus on sustainability, excluding the information already reported in the annual report and

corporate governance report, as presented by Ms. Baghuis at the beginning of the

session.

Also, we acknowledge the meaningfulness of this view, namely that the management

layers of the companies have impacts onto the social environmental factors.

However, firstly, the items to be disclosed should be more selectively chosen and within a

simplified structure so that the social and environmental impact of the management layer

of a particular company can be more straightforward to readers of the report. Secondly,

relevant policies and organizational structures for the G4 level disclosure are not yet

established in most Japanese companies. Therefore, their corporate managers need to be

educated on what global issues exist and why these issues matter to them in order to

proceed. The idea of disclosure stated in G4 is effective to obtain the managers’

endorsement, but due to the current level of complexity and the numerous existing details,

the impact of the disclosure seems be reduced by half (from the companies’ view point).

Therefore, the items disclosed need to be simpler and structure/correlation between the

items should be more straightforward.

4. Transparency

Although general contents in the annual report and the corporate governance report are

out of scope, if what matters here is ‘Transparency’, then it would be even more necessary

to define what information should be transparent with further clarity, and not just limit it to

that of Environment Social Governance, ESG.



10

It is obvious that Transparency is effective for improving corporate value and confidence

in the market within many countries including those in Europe. In Japan, currently, the

majority of corporate managers are reluctant to disclose information beyond that which is

mandated as legal obligation, and also the Governance of this process is considered to be

one of their weaknesses. Actions need to be taken in order not to be left out of the global

trend.

In respect of Transparency, the disclosure standard should be prepared with a clear and

simple necessary procedure, including specific directions, such as ‘what action should be

taken’ or ‘what information should be disclosed’.

Overall, there is an underlying concern over ‘the cost benefit for the information users’.

Lengthy information is not efficient, even though it is accurate. Good balance between the

cost of information collection and right judgment/decision available based on that

information is the key concern. We expect the G4 to be a clear and simple disclosure

standard.

2nd

Discussion Group Leader: Cetus & General Press Inc. Yoshihiko Yamabuki

1. Background

The concept of ‘Corporate Governance’ is not correctly recognized in Japan. Thereby,

it has not been understood through a shared awareness. Accordingly, Japanese

companies cannot be fully responsive to those economic, societal and environmental

demands.

The disclosure items proposed for G4 seem to weigh too much on Governance.

In our view, the majority of Japanese companies will be able to disclose these items

‘formally’, though it is unclear if that disclosure is conducible to the sustainability. The

disclosure items derived from general companies or a single common model in Europe

may not be able to fully capture the strength and weakness of actual corporate

governance. Also, frequent use of the term ‘ESG’ (Environment, Society, Governance)

may give an impression that the expected disclosure efforts are excessive and beyond a

company’s capacity. Therefore, we believe that goals which are to be attained through the

governance should be disclosed as material items, for example continuity and stability.

2. Disclosure of ‘how any system in place is actually effective’ is fundamental

We agree with the point made in the first half of the discussion, namely that ‘essence

should be communicated’. For reporting about the governance, a description of ‘how

governance systems in place are actually effective’ is indispensible unless the reporting is

just for the sake of formality. Any request for information about the governance system or

relevant rules and procedures may be easily responded to by Japanese companies.

Nonetheless, any questions asking about ‘how’ would be challenging or painful, for it is not



11

clear to them what is to be described, and then, what should be disclosed as reality.

Regardless of the expected challenges for the Japanese companies, we expect the

‘how’ related governance items will better reflect the ‘essence’ of the companies.

For example, a family-owned company is recognized rather negatively in terms of rigidity

of the organizational procedures and response to changes; while relatively positively in

terms of continuity and stability.

Whether good or bad, the remuneration system is embedded in a typical Japanese

management style and philosophy, which does not suit discussion.

3. There should be some items that can educe strength of the Japanese corporate

governance

Being requested to disclose the information aligned with a single governance model

would possibly cause a sense of resistance, for it sounds as if there is no liberty in the

choice of disclosure method.

Governance systems in Japan in general have a ‘middle-up’ rather than a ‘top-down’

style. There may be variables in the governance element in different countries, which do

not fit within the single unified model. The items of the disclosure should be able to capture

such unique strength.

Likewise, strengths of the family-owned company above mentioned, such as continuity,

stability, and long-term growth should be captured and evaluated through the disclosed

items.

Also, the group agreed that the consultation process between the stakeholders and

Board of Directors and the relationship with Outside Directors are important information

which are to be covered across different governance systems.

A-2. Disclosure on Management Approach

1st

Discussion Group Leader: So-Tec Consulting Inc. Ms. Mizue Unno

1. Overview

GRI Guidelines are providing an effective orientation:

Before discussing based on the predefined questions, the group decided to start with

more basic questions, such as ‘what is the purpose of generating the CSR report?’, ‘what

is the meaning/significance of that activity?’, and ‘is it meaningful to follow the GRI

Guidelines?’. The purpose of this pre-discussion is warming-up the exchange, given that

not all member of the group fully agreed with these guidelines.



12

Though there were variations in opinions, including some negative views, we confirmed

that there is a consensus that the GRI Guidelines are a useful tool for learning the CSR

activities at the leading global companies, and for undertaking CSR initiatives at one’s own

companies/organizations.

2. Management Approach

Management Approach: an important part of the Guidelines

4 -steps approach: appropriate

Missing item: Corporate philosophy should be included at the beginning, for it is the basic

premise of the company

a. The proposed revision toward G4 is based on items introduced in G3, with the

intension of bringing in further clarification and details for accuracy. From the

companies’ perspective, we agreed that it is necessary and important to have the

Management Approach in the disclosure category. Some companies have their own

indicators and they may feel uncomfortable to simply align them to the GRI indicators.

Also, in general, it is absolutely necessary for the company to have information which

can support their rationale for ‘why certain items are material’ to the companies. The

Management Approach section can mitigate such a perceptual gap felt by the

companies.

b. To the 4 steps specified here, namely (1) what are material issues for the company;

(2) why it is material to the company; (3) how those topics are managed; and (4) if

PDCA is properly functioning, we all agreed, without any particular disagreement.

There was no time to further discuss each step in detail.

c. Overall, the Management Approach is positively accepted in the group. However,

we found a big item missing, and, therefore would like to make one proposal.

As the first item of the Management Approach, the basic premises of the company

should be included. The corporate philosophy, the raison d’etre of the company since its

establishment, the principles and vision of the corporate operation, or the fundamental

sense of value are the underlying essence and drivers for the company as they engage in

CSR activity and sustainability, or implementing CSR management.

Many Japanese companies have cherished the idea of ‘kyosei’ (living and working

together for common good) and of the ‘public institution’ as a part of their corporate

philosophy since the time of establishment, through which they have historically included

the social factors into the corporate management. Therefore, it is significantly important for

the companies to state their corporate value (basic premises) in the reports. We strongly

recommend that the guidelines should clearly state the importance of describing such

corporate values and presenting a company’s current business model, presumably

reflecting the sustaining value.



13

Clarifying the flow of ideas toward selecting material issues and extending the flow to the

steps from their corporate philosophy seem to be necessary processes. Due to the time

restriction, we could not discuss how to describe/present the information in the additional

part we proposed. However, we all agreed that this additional information will facilitate

better representation if the positive elements of the Japanese companies.

3. Others

a. It make sense to a company to describe the Management Approach in narrative, but

external use of the information, especially by SRI surveyors who compare companies,

may not read the narrative description.

b. There is a concern that even though the information is disclosed, some users may not

utilize it unless it is easy to compare. (One of the participants from a company

mentioned that, in reality, general users tend to make judgments based on the

information easily available at data base level regardless of the efforts of GRI

promoting the materiality process. That tendency will not change even after G3. The

comment was made as a potential challenge to GRI.)

At the same time, the Management Approach information through a standard format

will not sufficiently convey the characteristics of the company. Therefore, it may require

a step by step improvement approach in the future.

2nd

Discussion Group Leader: Brain Center Inc., Mr. Takao Hiraishi

Incorporating the idea of time axis

a. We understand in the process of selecting Materiality, more weight is placed on the

‘impact’. As far as the ‘impact’ is concerned, it may require a ‘time axis’: for example, in

the financial report, the performance goal is fixed to a certain timeline in ‘the mid-term

management plan’. What is intended is to explain, ‘given a limited timeline’, ‘what are

the risks and challenges for achieving certain goals’, and ‘how the

performance/activities will be managed’. Our idea is to implement such ‘time-fixed’

approach to CSR and Management Approach.

b. Many CSR/ Sustainability Reports tend to set a long-term view for important issues.

However, with 10-, 20-, and 30-year time scales, management policies on these issues

may tend to be inevitably conceptual and abstract.

2. Consideration of risk probability

a. Themes to be reported in the Management Approach are more likely to be ‘risks’ than

‘opportunities’. This implies the importance of calculating risk probability.

b. The higher the risk, the stronger the management focus: Nonetheless, even if social

interest is high in a certain issue, the management will find it difficult to make

commitment, unless calculating risk probability is low.

3. Improvement for G4 principle contents

a. The current document is too principle-oriented. Since this is a guideline for reporting,



14

contents should be greatly simplified, otherwise it is hard to attain the intended level of

information disclosure.

b. If companies end up with different styles in their reporting as a result of strict

adherence to the principles, it would rather weaken their ‘comparability’.

4. Others (As personal views of Group Leader Mr. Hiraishi)

a. The Management Approach is a mirror of the corporate management. Therefore, the

CSR department, normally relatively close to the corporate management, needs to

collaborate with other departments like Corporate Planning or IR, and inform and

activate the corporate management.

b. Based on such a view, the direction of the ‘integrated report’ is becoming more

important.

A-3. Supply chain

1st

Discussion Group Leader: CSO Network Ms. Kaori Kuroda

1. Definition of Supplier

Possibility of including ‘Transportation’

a. There are some areas which overlap and are not easy to comprehend. Therefore, it is

better to define classifications based on categories. Also, it was mentioned that

‘Transportation’ should be included, along with ‘Distribution’, which is currently

included.

b. Relationships pertaining to the supplier differ between each industry. For example,

some industries sustain longer-term relationships, but, in industries like the food

industry, the relationships with suppliers will be subject to change in order to ensure

stable procurement under changeable conditions affected by situations such as

draught. The variety of the relationship with suppliers needs to be taken into

consideration.

2. Others

a. Understanding how to make a balance between corporate competitiveness and

information disclosure is critical. What should be disclosed and to what extent out of all

the information in hand, which includes some confidential information, depends on the

individual company.

b. It may be ideal if a company can emphasize key messages on the reporting form which

is structured based on the principles.

c. It is not clear how the disclosure of information based on the G4 may enhance the

corporate vale and improve contributions to society.

d. It would be challenging to convince the management, since the reporting activity and

the management of the company is not completely linked.

e. It may be necessary to disclose whether a company is practicing ‘fair price’ trading

(perhaps in the section of Product Responsibility)



15

2nd

Discussion Group Leader: Hitachi Ltd. Mr. Keiichi Ushijima

1. Overview

・Excessive information disclosure of supply chain affects competitiveness.

→ Balance and careful consideration is required for the way information is to be

disclosed.

・Impacts can be given only to the Tier 1 based on contracts. How far the scope of the

influence can be extended depends on the power relationship.

・The current G4 (Draft) includes many indicators which are questionable in terms of how

they can improve the corporate values, the suppliers’ values, and the social values.

a. Supply chain management impacts on the competitive advantage of a company. Since

the information related to procurement (such as from where, how much, at what price,

and in what quality transactions are conducted) is critical especially for the quality and

cost competitiveness of manufacturers, there is a resistance to this kind of disclosure.

b. In reality, only Tier 1 suppliers can be controlled by the contract-based relationships,

though there would be room for discussion with regards to indirect influence. The

suppliers are also independent business organizations, so, therefore, if they have more

power, then information about them may not be released. Situations change depending

on power relationships between suppliers and customers, and anything beyond the

contract terms would especially be a challenge. This is the reality in the business

environment that should be fully understood.

c. Based on what is mentioned above, we expect the G4 indicators to be ‘win/win/win’

indicators for three elements, which are, namely, corporate value, social value and

suppliers’ value, and to be cross-utilized among them. Unfortunately, the current set of

indicators does not seem to have such a nature. Since SCM is critical for business

management, normally a company has already defined its indicators. For example, cost

of goods, ratio of overseas production, number of suppliers audit and the results in the

CSR procurement areas are specified as common indicators. These indicators are

defined for the purpose of enhancing corporate value and sharing the value with

societies, which are often utilized internally for managing PDCA cycle. Requests of

information disclosure with additional indicators which would not create additional

corporate value and/or social value are costly and burdensome to the companies.

2. On Question 1.

Do you consider the proposed definitions of “supply chain” and “supplier” appropriate and

complete?

a. The definition of the terms seems to be fine. However, in order to provide guidance and

insight on the information disclosure and reporting of the companies, the definition had



16

better to be presented as a certain criteria based on actual business transactions, for

example, as a criteria focusing on the Tier 1 suppliers, from which materials and parts

are purchased. Otherwise, disclosure and management efforts merely increase the

amount of meaningless work,.

b. The current G4 (Draft) includes many materials for facilitating disclosure, yet is still

vague in terms of the scope of the disclosure. In order to serve as guidance for

reporting, further steps may need to be taken, such as focusing more on the key factors.

Nevertheless, this comment does not deny the current definition of the terms.

3. On Question 2

Do you consider the proposed supply chain-specific Indicators to be effective measures for

performance and feasible to report?

Many items, which are difficult to find and disclose

a. There are many kinds of information rarely founded or disclosed. Large manufactures

have more than 10,000 companies as direct suppliers. Therefore, what matters is a

balance between the necessity of disclosure, motivation, effect, and cost associated

with disclosure.

b. The G4 (Draft) includes indicators like ‘Location’ or ‘Monetary Value’, which measure the

degree of economic contribution to particular local areas through the supply chain. They

are sensible indicators for the inclusive business, but may be not be so useful for the

general supply chain. Positioning of these indicators seems rather uncomfortable at

present.

c. As mentioned above, if procurement sources and costs are easily assumed based on

the disclosed information, the competitive advantage of the company would be

threatened, and, therefore, many people will have strong resistance to the contents.

The definition of the word ‘local’ used in “locally owned supplier” is rather vague.

(For example, it is not clear whether ‘local’ means locations other than the head

quarters, or has such meanings as the location of the source suppliers for

manufacturing sites, or the location of the source supplies for markets. In any ways it is

nearly impossible to match the place of production, the place of consumption and the

place of procurement all the times in the global value chain.)

4. On Question 3:

Do you consider the proposed disclosures related to supply chain appropriate and/or

complete?

Maintaining a healthy competitive environment and expecting a balanced information

disclosure

Pursuing all the contents in the guide may threaten the healthy competitive environment.

Therefore, our group expects G4 to ‘indicate and guide the balanced information disclosure

while sustaining the healthy competitive environment.’ As mentioned at the beginning, the



17

supply chain is the key for the strategy.

5. On Question 4:

Do you consider the proposed guidance provided to support disclosure on supply chain

related issues appropriate and/or complete?

a. The content of the word “guidance” makes sense. However, there seems to be room

for reconsideration of whether or not what is stated here may contribute to resolving

fundamental social issues and environmental issues.

b. If collecting and disclosing information may serve as an incentive or contribute to

resolve the issues, then the ‘win/win/win’ relationship would be created among

management strategy/social value/suppliers, as mentioned earlier. However, on the

issue of human rights, for example, many of the indicators here would be effective for

resolving the human rights issue in supply chain, when they are adopted for

management and disclosure.

6. On Question 5:

Do you consider the proposed supply chain-related references appropriate and complete?

Since there are only few reference items in the Supply Chain, we have no comment. In

some cases it may be better to put all the references at the end of each chapter, rather

than inserting them after each section.

A-4. Boundary

1st

Discussion Group Leader: E-Square Inc. Mr. Hiro Motoki

1. Value Chain Map

How should the value chain map be drawn?

・ It is a good idea, but the techniques involved should be demonstrated

・ How should a picture that expresses a sense of the level be drawn?

・ Need or clear distinction: ISO26000 = Action Guideline, GRI = Reporting Guideline

a. As one of the biggest changes in G4, a step of drawing a value chain map is added

prior to the conventional step of selecting materiality. How the value chain map should

be drawn is to be pre-determined before starting the process. In the group discussion,

we concluded that direction of this idea is excellent and it is very important to capture

the process in the value chain. However, defining the technique of how to draw the map

is the challenge. .

Many approaches/techniques will be available. How to simulate the value chain and

whether to conduct stakeholder hearings/stakeholder dialogues/public comments in

order to identify issues and relevant aspects are issues for consideration. If a company

is not sure what approach/technique to take, it may spend too much time before even



18

starting to draw the map. Therefore, a clear approach and appropriate technique

should be indicated.

b. The value chain map provided in G4 is quite rough. There are comments that mere

straight lines used for the map seem to be a little unrealistic. Also, since the most

up-stream point starts with “Local Community” we presumed that the map is

representing a case of the extracting industry. However, ‘Local Community’ can exist

at multiple locations, like at the extracting sites, in any Organizations in the map, our

companies, and at Customer at the end of the down-stream. In some cases ‘Local

Community’ should be located in parallel to the entire value chain. It will be confusing,

unless the guideline provides a clear method for these technical matters.

c. The mapping can be positioned as a pre-task for ISO26000 due diligence. The entire

value chain can be simulated first, then due diligence and evaluation follow. Though G4

does not mention ISO26000, clear distinction between GRI as a reporting guideline and

ISO26000 as action may be helpful. Since there are many companies engaged in

ISO26000, the importance of mapping at this point will be effectively communicated.

2. Mapping Effectiveness

Value chains vary between different business: How much is to be represented in the map

a. We agree that the mapping is effective for identifying issues in the value chain and

materiality topics.

b. However, the actual drawing may cause challenges. For example, how to evaluate

multiple value chains associated with each business company under a single holding

company? Even in one individual company, different business units may have totally

different value chains. Clarification seems to be required, with regards to the expected

level of details captured in the map, in order to prevent confusion.

3. Clarity of the terms “Aspects” and “Topics”

Is it clear what level of detail is indicated with the term “Aspect” (regarding the

relationship among Aspects, Topics, and Materiality)?

Answer: ‘NO’ - it is hard to understand the difference between these two words.

a. The interpretation of these two terms varied among the group members. “Topics” can

be easily agreed as issues of sustainability, while “Aspect” can to be captured

differently according to levels, and each person may have different interpretations.

Further clarification is required to avoid confusion.

b. For example, the difference in the relationship between Aspects and selected items

through Materiality, or relationships with the indicators is not clear. G4 used to present

a chart on p294, yet it may no longer bee used since the chart is deleted. The

relationship between the terms “Aspect”, “Materiality” and “Topics” should be clearly

mapped-out based on precise definitions.



19

4. Overall

There should be no room for interpretation, for this is a guideline. The reality that not all

the strategies and thoughts can be disclosed should be taken into consideration.

a. Since G4 is a guideline, the room for interpretation should be minimized.

If interpretation is accepted, discussion over the interpretation with other companies

may take a large amount of energy and time.

b. Since G4 is a reporting guideline, it gives an impression that all information should be

disclosed including strategic measures and thoughts. In reality, however, a company

cannot and is not obliged to disclose everything, such as strategic confidentiality

matters. In order to avoid misunderstanding, some statement should be added to

clarify the nature of information that G4 is intending to reveal.

2nd

Discussion Group Leader: Cre-en Inc., Ms. Ayako Sonoda

Our discussion on Boundary extended also to more basic matters:

1. Issues

Reporting activity itself has become a purpose, and is not connected to PDCA cycle.

・ Weighed too much on to western values and logic

・ Expecting something inspiring ‘passion’ → Bright future (current impression: too

academic/theoretical)

・ Globally, it is a time to re-consider Sustainability

・ Visible interface with business activities

a. There were 3 participants from totally different industries (IT, Pharmaceutical, and

Mining) with different business models, and their comments were common in the

following points: the reporting activity itself has become a goal; they had no time to

conduct activities; and not all the activities are linked to the report, nor actually used for

PDCA cycle management.

b. Maybe it is because of the gap between the Asian and Western sense of values, but

there is an impression that Western standards are forcefully implemented. Also, the

question of how to harmonize the perceptual difference based on the general ideas that

human nature is fundamentally good as generally believed by Japanese people versus

human nature is fundamentally evil as believed in the West arose.

c. Expectations of GRI: Creating the guideline full of Passion. Many members commented

that currently GRI tends to be very academic, but if the guideline can cheer up people

and indicate a bright future by just reading it, or if the guidance can show companies the

direction to go, through which the companies can be motivated for change and the

creation of sustainable societies, then the guideline will be more efficiently utilized and

appreciated. Originally, this guideline was standing upon the consideration pertaining to

what sustainable global environment and human society are, and how human society

can be developed with the limited resources on this globe. Emerging earnest

expectations of the companies for collaboration was also addressed at that time.



20

Adding such background information may encourage people to utilize this guideline

more effectively. Considering changing market environments and consumer behavior

imposes harsh price competition on companies, and it may be a good time to

reconsider the meaning of Sustainability today.

Some members of the group attended the Rio +20. The key theme of the Rio+20 was

‘Sustainable Consumption’, which is also included in ISO26000. In fact, 10 years ago in

the Summit in Johannesburg the issue of ‘changing production and consumption

models’ was raised, asking the companies to seek new economic models other than

mass production and mass consumption.

In the reconsideration of Sustainability, we may have to discuss how to promote

Sustainable Consumption by encouraging both companies and consumers, and how to

create a new business model.

d. Promotion will become easier with indicators visualizing interface with business that

represent competitive advantages and strengths, or contents and anything supporting

competitiveness, especially for the Japanese companies, will be useful. Positive

elements of the Japanese management style and the governance style of the

family-owned business need to be further communicated.

2. On Mapping:

・ More freedom than detail requirement

・ Defining a concrete Boundary and techniques in Sector Supplement

・ Presentation of best practices in each industry

a. Understanding that Mapping is a very effective method, some liberty in mapping should

be acceptable rather than restricting this process through detailed directions (since

many indicators and complicated contents are already involved.)

How far the actual scope of the mapping should go, whether to Tier 1 or to Tier 3 or

further more, is subject to change according to the industries and business, as well as

level of globalization the company. Therefore, there should be some concrete

directions or indicators given in Sector Supplement for the use of defining the boundary.

b. Some companies may have a mapping for biodiversity. Perhaps a mapping can be

used as one of the layers to present social relationships holds in labor environment or

human rights, or used for reflecting environmental factors in parallel. Once best

practices and know-how are cumulated, a simple and effective method will be found

through serious efforts of Japanese companies, rather than relying on the volume of

data.

3. How to handle unexpected impacts within the Boundary (the Great East Japan

Earthquake)



21

a. For the harmonization with the action guideline ISO2600, continuous effort is

prerequisite. However, at the same time, how to respond to unexpected impacts should

be also considered. Japanese companies received an enormous amount of impact

through the Great East Japan Earthquake and the flood in Thailand. Damages to the

supply chain had affected the companies’ business operations, and, therefore such

unexpected impacts may need to be considered in the boundary.

b. Of course, while it is difficult to assume size of the impact of a tsunami or another

natural disaster likely to happen once in 100 years, it should be included in the scope

of boundary, as long as there is a likelihood of future occurrence.

A company of one of the group members has a factory in Fukushima Prefecture. The

factory operation was suspended for a certain period, which caused problems for

patients who needed to take a special drug manufactured in the factory. Intermittent

operation of the factory may not be acceptable for it causes a problem to the stable

supply of the medication. Reflecting such experience, unexpected impacts to the

business operation may need to be considered in the boundary. We may need to

consider not only the boundary related to business, but also socio-environmental

impacts and world affairs. We did not have time to discuss how to incorporate such

unexpected events into the boundary, yet we shared valuable opinions on this topic.

A-5. Application Level

1st

Discussion (Group Leader: Cetus & General Press Inc. Mr. Yoshihiko Yamabuki)

1. On Question 1

Do you agree with the proposal to discontinue with the Application Levels and to replace

them with criteria that define when a report has been prepared “in accordance with” the G4

Guidelines?

・ Application Level Check will not be so necessary.

・ It is unlikely that CEOs’ signature for “In accordance with ～”

・ Effective to the Application Level, for enhancing disclosure level

・ Potentially linked to the internal improvement activity, once the common standard is

provided.

A+ is the industry standard in the mining industry → To be continued

・ Concerning less information disclosure, under the current trend of emphasizing

Materiality and Integrated Report

・ The process of identifying Materiality through the Application Level is effective

→ An application Level is effective for improving the disclosure level

The group had a very intensive discussion.

Though an original question was simple and much discussions came out, it developed

along with the topics of ‘Application Level’ and “In accordance with~” and included

assessing the acceptability of such wording.



22

a. Only a few companies in Japan have conducted Application Level checks

appropriately:

This implies that this check does not make a significant difference. Instead, it is

important to improve the status of GRI. GRI should position itself as a reporting

guideline harmonized with other OECD or ISO26000 guidelines. The GRI mark should

be recognized with a certain status and appeal to the society that the GRI mark will

benefit many stakeholders.

b. Revision of the phrase “In accordance with ～” has posed more realistic challenge to

Japanese companies. The idea of getting signatures from CEOs to prove their

adherence would be very difficult in Japan although the group thought otherwise at the

beginning. The final answer to this question is NO (from Japan), and the reasons are

stated as follows:

b-1. For the purpose of improving the disclosure level, the Application Level Check has

been effectively utilized, especially in Japan after G3 was issued in 2006.

b-2. The presence of such common criteria facilitates the motivation of internal

resources and sharing of the same awareness/vision. Sharing the common

understanding for the needs of the disclosure and aligning their vision, paves the

way to improve the level of disclosure. The application Level is an effective stage

for initiating such a cyclic process in the company.

b-3. In the mining sector, Application Level A+ is recognized as the industry consensus

or rule. Such positioning of the Application Level will also be effective to the other

industries/businesses.

b-4. GRI as a whole has been evolving and delivering various forms such as

Materiality and Integrated Report. However, we are concerned that greater

emphasis on Materiality and Integrated Report may be resulting in lower levels of

information disclosure, despite the fact many companies have been successfully

improving their discloser levels by utilizing the scheme of the Application Level.

Just for identifying Materiality, the Application Level may not be necessary.

b-5. An ideal process will be using the Application Level for identifying Materiality, and,

in the case of Japan, it may suit the current environment. For the purpose of

improving contents and the quality of the information, we would like to

recommend that new reporters should also effectively utilize the Application

Level.

b-6. One of the reasons of discontinuing the Application Level is misunderstanding that

some companies utilize the Application Level to assess their performance levels.

However, if the problem is merely the wrong usage, it should be pointed out and

corrected. For us, loosing truly useful tools/methods because of simple

misunderstanding does not make sense.

2. On Question 2

Do you support the introduction of transitional provisions to allow new reporters two

reporting periods in order for their reports to gradually be in accordance with the G4



23

Guidelines?

・Effective to other regions as well as new reporters.

When new reporters (especially companies in emerging countries in Asia) gradually raise

the level of disclosure, use of the Application Level Check will be effective. Based on the

experience of Japan, we came up with the conclusion that the step by step approach for

improving disclosure and activity levels based on fixed criteria and standards was effective.

2nd

Discussion Group Leader: Burberry Japan Mr. Masaki Wada

1. On Question 1

Do you agree with the proposal to discontinue with the Application Levels and to replace

them with criteria that define when a report has been prepared “in accordance with” the G4

Guidelines?

a. The Application Level is effective in terms of information disclosure and use as a

guideline, and it is necessary. (There are also some opinions, such as ‘it is necessary

for dissemination within a company’, and ‘is necessary for obtaining the CSR report

budget) The group members agreed that the Application Level is necessary.

b. There were some comments that denied the need of the Application Level: in order to

improve competitiveness of the companies in real terms, it would be better without the

Application Level.

c. Signing “In accordance with~” may be difficult. Some commented that there is a

resistance to give this kind of signature and honestly do not want to sign.

d. Per the request of the group members, I report my personal comment here. For me the

brand reputation of GRI is rather questionable.

For example, once the Levels (Level A, C, or Application Level) are clearly recognized

and endorsed, it would be easier for companies to start reporting with the Application

Level. Without the Application Level, the necessity of GRI guideline would be

questionable.



24

APPENDIX 1

Appendix 1 GRI G4 PCP in JapanList of Participants

2012, Aug, 23rd

attendance Name Job Title Department Company / Organization

1 * Reiko Taniguchi Fundraising Coordinator Amnesty International Japan

2 * George Yoshimoto ManagerCSR Sustainability Team, CSR Sustainability Department,Global Legal & Compliance Division

ASICS Corporation

3 * Rieko Tanaka

4 * Hiro Motoki Chief Executive E-Square Inc.

5 * Keisuke Ota ManagerCSR Promotion Office, CSR and EnvironmentalManagement Promotion Division

NEC Corporation

6 * Hitoshi Morotomi Evecutive Manager Head, Auditors Office NTT Com Solution & Engineering Corporation

7 * Masaru Arai Chair Social Investment Forum Japan

8 * Matsuzaki Minoru ManagerCSR Department, Group Compliance Division, CorporateGovernance Office

OLYMPUS CORPORATION

9 * Emi Mashiko International Economy Division, Economic Bureau Ministry of Foreign Affairs

10 * Ayako Sonoda President Cre-en incorporated

11 * Kimie Itaya Manager Sustainability Communication Group Cre-en incorporated

12 * Kayo Ito Senior Staff Sustainability Communication Group Cre-en incorporated

13 * Toshihiko FujiiThe Research Institute of Economy, Trade andIndustry(RIETI)

14 * Nobuyuki　HiratsukaDirector for ManufacturingIndustries Policy

Manufacturing Industries Bureau Ministry of Economy, Trade and Industry

15 * Miyuki Hayashi Accounting Standard ChiefEconomic and Industrial Policy Bureau, CorporateAccounting, Disclosure and CSR Policy Office

Ministry of Economy, Trade and Industry

16 * Shuhei Yoshimoto ResearcherEnvironmental Industries Office, Industrial Science andTechnology Policy and Environment Bureau


17 * Natsuki HirabayashiEnivironmental Ecxonomy Office, Industrial Science andTechnology Policy and Environment Bureau


18 * Toyoharu Kobayashi Principal Deputy DirectorEnvironmental Industries Office, Environmental PolicyDivision, Industrial Science and Technology Policy andEnvironment Bureau


19 * Tomoko Suwa Assistant ManagerCSR Promotion Dept., CSR., Corporate Communication &Branding Div.

Konica Minolta Holdings, Inc.

20 * Sohei Motoyama Head CSR, Public Affairs sanofi-aventis K.K.

21 * Tomoko　Sakano Secretary Sustainability Forum Japan

22 * Yoshihiko Yamabuki General Manager Cetus & General Press Inc.

23 * Kaori Kuroda Executive Director CSO Network Japan



2012, Aug, 23rd


24 * Mitsuko Orikasa Section LeaderCorporate Social Responsibility Section, CorporateStrategy Planning Dept.

Nippon Steel Engineering Co., Ltd.

25 * Hisako Komai Executive Director Council for Better Corporate Citizenship (CBCC)

26 * Jun Iwata Manager Planning Team, Environment & CSR Dept. Sumitomo Corporation

27 * Satoshi Dairaku Manager Safety & Environment Control Dept. Sumitomo Metal Mining Co., Ltd

28 * Hidemi Tomita General Manager Corporate Social Responsibility Department Sony corporation

29 * Mizue Unno Managing Director So-Tech Consulting Inc.

30 * Jun Sato Assistant General Manager CSR office, Corporate Communication Division Dai Nippon Printing Co., Ltd.

31 * ASAMI KOKUFUDA Associate Manager CSR Department, Legal Affairs & CSR Division Daiichi Sankyo Co., Ltd.

32 * Makoto Teranaka Visiting Professor Faculty of Contemporary Law Tokyo Keizai University

33 * Yoko Okawa Senior Consultant Communication Design Division Dentsu Public Relations Inc.

34 * Isao MATSUDA Creative Director Toppan Editorial Communications Co., Ltd.

35 * Kanako Nagai Senior Specialist Promotion, JP Enterprise/SMB Marketing Trend Micro Incorporated

36 * Yuko Tsutsui Deputy General ManagerCSR Coordination Team, CSR Coordination Group,General Affairs/CSR Headquarters

NYK LINE

37 * Keisuke Takegahara General ManagerEnvironment Initiative & Corporate Social ResponsibilitySupport Department

Development Bank of Japan Inc.

38 * Masahiko Kawamura Senior Research Fellow Insurance Research Group NLI Research Institute

39 * Hiroya Ichihara Assistant Group Manager Environment & Social Contributions Division NIPPON EXPRESS CO., LTD.

40 * Kiichiro Yokoyama Manager Corporate Communications Department Nomura Research Institute, Ltd.

41 * Yuko Deguchi Corporate Citizenship Department Nomura Holdings, Inc.

42 * Masaki WadaEthical Trading Manager,Japan

BURBERRY JAPAN K.K.

43 * Toshiaki Isoda Councilor CSR Office Panasonic Corporation

44 * Keiichi Ushijima Manager CSR Promotion Devision Hitachi, Ltd.

45 *MOTOKOKAWASAKI

Operations Manager CSR Group, Corporate General Administration Div. FUJIFILM Holdings Corporation

46 * Yukiko Nakagawa FUJITSU LIMITED



2012, Aug, 23rd


47 * Takao Hiraishi Managing Director BRAIN CENTER INC.

48 * Yukihiko Kakutani Assistant Manager Environment and Safety Planning Office Honda Motor Co., Ltd.

49 * Nanami KosekiCSR Strategy group, Corporate Social ResponsibilityDepartment, Presidential Administration Office

Mitsubishi Heavy Industries, Ltd.

50 * Yukari HiraiGlobal Corporate Social Responsibility Office, LegalAffairs Department

Mizuno Corporation

51 * Sakae Tanno Deputy General Manager CSR & Environmental Sustainability Dept MITSUBISHI ESTATE CO., LTD.

52 * Arata Sato President UNIVERSAL COMBO Inc.

＜欠席者　/　absence＞

absence Toshihiko Goto Sustainability Forum Japan

absence Hiroko Ozawa Senior Manager Integrated Reporting Department Ernst & Young ShinNihon LLC

absence Koichi Kaneda. Senior Director CSR Corporate Communications Department Takeda Pharmaceutical Co., Ltd.

absence Kenji Shima Mitsubishi Chemical Holdings Corporation

absence Setsu Mori President “alterna” Magazine


The Report of the GRI G4 Public Comments Process WorkshopCaux Round Table Japan jointly hosted the...

Documents

Transcript of The Report of the GRI G4 Public Comments Process WorkshopCaux Round Table Japan jointly hosted the...