ACCA welcomes the opportunity to provide views in response to the exposure drafts for the first phase ‘Employment practices and conditions’ of the GRI Topic Standards Project for Labor comprising the Employment (EMPL) exposure draft, Remuneration and Working Time (REWO) exposure draft, Significant Changes for Workers (SICH) exposure draft, and Control of Work Standard Interpretation to GRI 2 exposure draft. We hope that our comments, which reflect feedback from our ACCA Global Forum for Corporate Reporting, are a helpful contribution to this process.
As sustainability-related standard-setting progresses, it is important to ensure that the reporting catalyses the necessary systemic change: that operational changes take place in the entities making these disclosures; better quality of information becomes available to investors, who will then use these disclosures to allocate capital more efficiently and responsibly. For this to happen, widespread application of integrated thinking by entities as well as integrative thinking by finance professionals are necessary.
ACCA has consistently advocated for a global approach to the development of sustainability disclosure standards which can provide a consistent and comparable global baseline to sustainability reporting around the world. To this end, we commend and welcome the Global Sustainability Standards Board (GSSB)’s multi-stakeholder approach and alignment efforts.
We thus strongly recommend that the ongoing collaboration and commitment between the GSSB and International Sustainability Standards Board (ISSB) to jointly identify and align common disclosures extends to this project as early as possible, so that it may inform and maximise alignment (ie with the same requirements and terminology) with the upcoming ISSB’s Human capital project, such that reporting organisations will eventually only need to prepare one set of sustainability-related disclosures. This in turn will better support harmonisation with other standards, frameworks and generally accepted principles, including ESRS S1 Own Workforce.
We also caution that careful consideration is needed in weighing the decision-usefulness and need for information at the proposed level of granularity against the practicality and cost of providing such information by reporting organisations, as there is currently a genuine risk of this being a burdensome disclosure at an inappropriate degree of granularity, both for preparers and users alike. In particular, it is important to understand why users might need this information, and how they intend to use it.
To read the response in full, please download the response document found on this page.