Do the NSE Sustainability Disclosure Guidelines align with the GRI Standards?

Since the unveiling of the Nigerian Stock Exchange’s Sustainability Disclosure Guidelines (NSE-SDGS) in March 19, 2019, all listed companies on the Premium Board have been mandated to reference the NSE-Sustainability Disclosure Guidelines when producing sustainability reports of their organisations’ environmental, social and economic impacts, starting from January 2020. Ordinary listed members are encouraged to produce sustainability reports which follow the recommendations of the guidelines. What the NSE has precipitated is the facilitation of gap analysis and production of reports by a important grouping of companies.

The questions, interlinked, that most of these companies, which are either multinationals or large indigenous businesses with international presence, are whether the NSE-SDGs is sufficient to produce a sustainability report that meets both local and international reporting standards such as the GRI Standards or if reporting organisations should separately produce different reports for the GRI Standards and the NSE-SDGs.

With these types of questions resonating in a space which we dominate, CSR-in-Action deemed it necessary to take some time to carefully look at the GRI Standards and the NSE Sustainability Disclosure Guidelines with a view to identifying areas of alignment and possible differences for users of both guidance. It is important to highlight that the NSE-SDGs were developed under close consultation with the Global Reporting Initiative.

In this article, we briefly explain how complying with all the necessary reporting requirements and guidelines provided in the GRI Standards sufficiently covers all the reporting requirements expected within the NSE-SDGs and automatically translate to full compliance.

We start by explaining the GRI Standards requirement for producing a sustainability report. The GRI Standards, the first and most universally adopted standards for developing sustainability reports, help businesses, organisations and governments to understand and communicate their impacts on issues such as climate change, human rights and corruption. This communication is done in the form of a report to the public and involves guidelines and standards that must be adhered to if the report is to be said to be developed using the GRI Standards.

For example, if an organisation wishes to produce its sustainability report using the GRI Standards and where it plans to claim that it has adopted the GRI Standards in writing its sustainability report, such report must be developed in accordance with GRI Standards specific guidance and requirements. Therefore, an organisation preparing a report has three options of reporting in accordance ‘Core’ or ‘Comprehensive’ or producing a GRI-Referenced report if it decides to use only select GRI Standards, or if they are unable to meet particular requirements of the GRI Standards.

To give better background, the Core Option report contains the minimum information needed to understand the nature of the reporting organisation, its material topics and related impacts, and how these topics and impacts are managed.

The Comprehensive Option builds on the Core option by requiring additional disclosures on the organisation’s strategy, ethics and integrity, and governance, and the organisation is required to report more extensively on its impacts by reporting all the topic-specific disclosures for each material topic covered by the GRI Standards.

Both options guide the reporting organisation through the process of preparing a sustainability report in which:

  • the Reporting Principles have been applied;
  • disclosures giving contextual information about the organisation have been made; and
  • every material topic has been identified and reported on.

Companies to consider themes and guidance provided in internationally accepted standards such as the Global Reporting Initiative (GRI) Standards in identifying material sustainability matters.

The NSE-SDGs’ general requirements focus on the following key areas which aligns with the four Reporting Principles for Defining Report Content in the GRI Standards:

GRI Standards Principles

NSE-SDGs General Requirements

Sustainability Context

Principle

Overall context on the internal structure, strategy, profile and governance of how the economic, environmental, social risks and opportunities are managed

Completeness Principle

Scope and boundary of the report

Materiality

Principle

Material sustainability matters and

how they are identified and managed

Stakeholder Inclusiveness

Principle

 

Stakeholder inclusiveness

Table 1: Alignment between the GRI Standards Reporting Principles for Defining Report Content and NSE-SDGs General Requirements.

Furthermore, the requirements contained in the NSE-SDGs Focus Areas, Principles and Core Elements which cover the guidelines’ Governance, Economic, Social and Environment (ESG) topics, are fully covered in detail in the 36 GRI Sustainability Reporting Standards which is grouped into 3 Universal Standards (GRI 101- Foundation, GRI 102 – General Disclosure and GRI 103 – Management Approach) and 33 Topic Specific Standards, with the GRI Standards enabling or requiring more detailed reporting.

The GRI Standards may also be used on organisations’ reporting on the Sustainable Development Goals, the Nigerian Sustainable Banking Principles (NSBP), the United Nations Global Compact Communication on Progress (COP), and other local reporting requirements for ESG and sustainability.  



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