In the sustainability and corporate social responsibility (CSR) “space” there is increasing pressure to report on triple-bottom-line issues through reporting frameworks, such as the GRI G3. There is a trajectory toward quasi-mandatory reporting by value-chain stakeholders and actual mandatory reporting by regulatory-bodies. Quasi-mandatory reporting is seen with the inclusion of GRI sustainability reporting as tracked by Bloomberg’s Index and other financial indices. Mandatory reporting is seen in South Africa, Denmark, and France.
This trend will impact organizational risk management in a number of ways. At a core and basic level, there is an issue of data quality assurance and data use. That is, are the data reported accurate? And how do you know? Is there any possible propensity to “greenwash” data? Is there a propensity to not report bad data? Has consideration been given to the balance between reporting and potential civil liability? Has consideration been given to the different data needs of stakeholders?
These are all questions that EHS/S and risk management professionals have been wrestling with for years, but not necessarily from a sustainability, CSR, or reputational risk perspective.
Consideration should be given to the ability of existing EHS/S and risk management structures to address these questions. With increased sensitivity about reputational risk, a rush toward more transparency should be grounded by strengthening risk management structures.
A place to begin doing this is to augment sections 4.4.3 (Communication) and 4.5.1 (Performance Measurement and Monitoring) of the existing 14001/18001 management system, with ISO 31000 sections 5.3 (Establishing the Context) and 5.4 (Risk Assessment). Key here is throwing the risk assessment net wide and then informing reporting decisions with criteria from 31000 section 5.3. If there are reporting “breakdowns,” these can be minimized if there is a robust 14001/18001/31000 integrated risk management in place. Such a system greatly reduces the potential for accidental green washing.
© Redinger EHS, Inc. (2010)