Public sector sustainability reporting:: Remove the clutter, reduce the burden

Mapping Global Reporting Initiative against public sector reporting requirements in Australia September 2012

About the Global Reporting Initiative Global Reporting Initiative GRI’s vision: A sustainable global economy where organisations manage their economic, environmental, social and governance performance and impacts responsibly, and report transparently. GRI’s mission: To make sustainability reporting standard practice by providing guidance and support to organisations. The Global Reporting Initiative (GRI) produces a comprehensive Sustainability Reporting Framework that is widely used around the world, to enable greater organisational transparency. The Framework, including the Sustainability Reporting Guidelines, sets out the principles and indicators organisations can use to report their economic, environmental, and social performance. GRI is committed to continuously improving and increasing the use of the Guidelines, which are freely available to the public. (See insert: GRI Sustainability Reporting Guidelines G3.1 – Reference Sheet for an overview of the GRI Sustainability Reporting Guidelines). GRI is an international non-profit organisation. All elements of its Reporting Framework are created and improved using a consensus-seeking approach. Stakeholder input to the Framework comes from business, civil society, labor, accounting, investors, academics, governments and sustainability reporting practitioners. This approach is intended to enable transparency and accountability, and to provide comparability amongst reporting organisations. By using GRI’s Framework, Australian public sector organisations will be able to compare their sustainability reports year-to-year with those of other agencies, both domestically and internationally.

Global Reporting Initiative Focal Point Australia GRI and St James Ethics Centre entered into an agreement in 2008 to establish a GRI Focal Point in Australia. The collaboration serves to strengthen the goals of both organisations – increasing the uptake of responsible business practice and making reporting economic, environmental and social performance standard practice. The Focal Point is funded by the Federal Government’s Treasury and CPA Australia, and hosted by St James Ethics Centre. .

Copyright This document is copyright protected by Global Reporting Initiative Focal Point Australia. The reproduction and distribution of this document for information is permitted without prior permission from GRI FPA. However, neither this document nor any extract from it may be reproduced, stored, transferred or translated in any form or by any means (electronic, mechanical, photocopies, recorded or otherwise) for any other purpose without prior permission from GRI FPA. Global Reporting Initiative, the Global Reporting Initiative logo, the Sustainability Reporting Guidelines, and GRI are trademarks of the Global Reporting Initiative.

Reference: Global Reporting Initiative Focal Point Australia (2012) Integrating Sustainability into Reporting - An Australian Public Sector Perspective, GRI Focal Point Australia, Sydney

Executive Summary Report overview • Australian public sector organisations are facing an ever-growing demand from different stakeholders to be more transparent and accountable about their economic, environmental and social performance, yet current reporting requirements and the lack of resources to measure their performance prevent further transparency and accountability.

• Corporations, stock exchanges, governments and other organisations are recognising the value of integrating sustainability into core strategy and business practice, and are adjusting their reporting accordingly.

• The process of sustainability reporting can add value and quality to management information, ensuring that pivotal performance information is disclosed publicly. GRI’s Sustainability Reporting Framework provides robust guidance to enable greater transparency and accountability in the public sector.

• The analysis shows that sustainability and GRI reporting brings the whole organisation into view – the social, economic and environmental context in which it operates. It also, if used appropriately, could lead to a decreased rather than an increased reporting burden on government – reducing cost and improving efficiency.

• There is strong alignment between current NSW public sector reporting requirements and GRI’s Sustainability Reporting Framework (specifically GRI’s G3.1 Performance Indicators).

• GRI’s Sustainability Reporting Framework is designed to provide flexibility to allow organisations to report on the sustainability issues that are most important to their operations and their stakeholders. Central agencies may consider providing guidance on minimum sustainability disclosures to ensure consistency across the government.

• G3.1 has 126 disclosure items: 84 Performance Indicators (mostly for quantitative measurement of sustainability performance) and 42 Profile Disclosures (for qualitative and quantitative information about the organisation itself). The analysis determined that of the 126 GRI disclosure items, 60 could potentially be answered either directly from general mandatory data (25) and/or with some modification using information and data from existing reporting requirements (35). A further 29 items could potentially be answered using readily available organisational information. However, 31 GRI disclosure items could not be readily answered using existing cross-government reporting (these included GRI Performance Indicators for biodiversity, human rights, society, product responsibility and economic performance).

Recommendations

• GRI Focal Point Australia encourages governments at all levels to lead by example and report with GRI’s Sustainability Reporting Framework – local, state, federal

• GRI Focal Point Australia encourages governments to require government reports to follow a minimum set of sustainability disclosures

• GRI Focal Point Australia encourages the Council of Australian Governments (COAG) to adopt a common sustainability reporting framework for the public sector in Australia

Why sustainability reporting? Six good reasons why sustainability reporting is needed in the public sector:

• The changing landscape of society – organisations today face heightened expectations around their wider role in society. • The role of government – agencies have a civic responsibility to properly manage public goods, resources and/or facilities in a way that supports sustainable development objectives and promotes the public interest.

• The need for transparency – public sector sustainability reporting provides a framework to link financial performance to the organisation’s use of, and impact on, the significant resources and relationships upon which it depends. It also guides the governance and ethical conduct of an agency, offering transparency and accountability benefits by requiring the reporting of the organisation’s key performance information.

• The need for global alignment – regulators globally are starting to talk about sustainability reporting and there is a growing list of national policies mandating sustainability reporting. GRI is the globally-recognised framework for voluntary reporting of sustainability performance – it provides an independent reporting framework that provides transparency, accountability and comparability amongst reporting organisations.

• The value of integrated thinking – integrating sustainability factors into an organisation’s decision making is an emerging trend internationally for both government and corporations. The International Integrated Reporting Council (IIRC), established by the Global reporting Initiative, the Prince of Wales’s Accounting for Sustainability and the International Federation of Accountants, is developing an integrated reporting framework that will help to bring together data that is relevant to the performance and impact of an organisation in a way that will create a more profound and comprehensive picture of the risks and opportunities an organisation faces, specifically in the context of the drive towards a more sustainable economy.

• The need to reduce reporting complexity and burden – sustainability reporting is not about adding more information for public reporting; it’s about making connections and holistic thinking, thereby removing the clutter and reducing the reporting burden.

Contents Gaining consistency in public sector sustainability disclosures

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The benefits of sustainability reporting

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International trends in sustainability reporting

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Sustainability reporting and the public sector

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Understanding Sustainability Reporting

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GRI’s Sustainability Reporting Framework

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Preparing for Integrated Reporting

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Mapping GRI against public sector reporting requirements

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Methodology – mapping reporting frameworks

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Mapping results – public agency reporting and GRI

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Conclusions & Next Steps

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More similarities than dissimilarities

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Next steps

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Appendix A: Table 2 - Mapping NSW public sector reporting against GRI disclosures

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Appendix B: Table 3 - Public sector and GRI disclosure descriptions and modifications

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About this publication This publication ‘Integrating Sustainability into Reporting – a Public Sector Perspective’ is an initiative of the Global Reporting Initiative Focal Point Australia (GRI FPA). The analysis has been undertaken by Manidis Roberts for GRI FPA. The aim of this paper is to promote best practice and improve the preparedness of public agencies for sustainability reporting. By using a consistent framework for sustainability disclosures, organisations have the potential to avoid unnecessary duplication in reporting and to stimulate harmonisation with existing reporting standards for the public sector in Australia. The paper maps mandatory public sector reporting requirements against sustainability reporting (specifically the core product of 1 GRI’s Sustainability Reporting Framework, the GRI G3.1 Guidelines) to highlight areas of complementarity. The paper is an outcome of the Australian GRI Conference on Sustainability and Integrated Reporting held in Melbourne in March 2012. Conference delegates identified the actions for governments in Australia: ‘Governments at all levels to lead by example and report in accordance with GRI – local, state, federal. To lead government reports will link to a clear definition of public value and demonstrate how existing strategic objectives link with their sustainability agenda/framework. Reports will address specified topics and the auditor general will have an assurance and oversight role, central agencies will ensure consistency of 2 reporting on material issues and between departments’. (GRI FPA, 2012) For the purposes of this report, the public sector includes departments, declared authorities, state-owned corporations, health services, local government and universities. All these entities are referred to as public sector agencies throughout this paper. The mapping analysis has concentrated on government departments specifically.

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Global Reporting Initiative, G3.1 Sustainability Reporting Guidelines, 2011.

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Global Reporting Initiative Focal Point Australia, Executive Summary of The Australian GRI Conference on Sustainability and Integrated Reporting, 2012. PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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Gaining consistency in public sector sustainability disclosures The benefits of sustainability reporting ‘Sustainability reporting and integrated reporting provide significant opportunities for innovation. As organisations become accountable for their sustainability performance and integrate non-financial issues into their business strategy, innovation occurs across operations. Sustainability reporting gives a wider view of an organisation that financial reporting alone. Informed by key stakeholders, sustainability reporting helps 3 organisations uncover key risks and areas for innovation’ (GRI, 2012) . Research has shown that organisational reporting influences behaviour. Sustainability reporting results in a broader explanation of performance than does traditional financial reporting. It makes visible an organisation's use of and dependence on different resources and relationships across environmental, social and economic spheres, as well as the organisation's access to and impact upon those resources. This information is critical to:

• a meaningful assessment of the long-term viability of the business model and strategy • meeting the information needs of government and other stakeholders • the effective allocation of scarce resources Current public sector reporting requirements may not be up-to-date, broad or connected enough to address these emerging and critical issues. The benefits for organisations that engage in sustainability reporting can include:

• operational efficiency • reputation management • social license to operate • stronger relationships with communities • employee satisfaction • improved risk management • long-term security • access to capital • minimised environmental and societal impacts

3 Global Reporting Initiative Focal Point Australia, Executive Summary of The Australian GRI Conference on Sustainability and Integrated Reporting, 2012.

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International trends in sustainability reporting Corporations, stock exchanges, governments and other organisations are recognising the value of integrating sustainability into core strategy and business practice, and are adjusting their reporting accordingly.

Corporate trends in sustainability reporting 4

The most recent KPMG International Survey on Corporate Responsibility Reporting (2011) revealed that disclosure on corporate economic, environmental and social performance has become ‘virtually mandatory’ among larger companies globally. The report reveals that over ninety five per cent of Global Fortune 250 companies (G250) provide sustainability or corporate responsibility reports. Eighty percent of the G250 use GRI’s Sustainability Reporting Framework. The number of top Australian listed companies reporting meaningfully on corporate responsibility has grown to fifty seven percent.

Regulatory Trends in Corporate Sustainability Reporting In 2010, GRI, the United Nations Environment Program (UNEP), KPMG and Stellenbosch University conducted a review of 5 mandatory and voluntary sustainability reporting standards and legislation in 30 countries . The review revealed that both international and national standards, codes and guidelines, as well as legislation for sustainability reporting, have been evolving strongly. As sustainably reporting increases internationally, so too does an increasingly dense regulatory network of international and national standards, codes, guidelines and legislation. The research revealed the following: • • • •

A total of 142 country standards and/or laws exist with some form of sustainability-related reporting requirement or guidance Approximately two thirds (65 percent) of these standards can be classified as mandatory and one third (35 percent) as voluntary A total of 16 standards with some form of reporting requirement at the global and regional level A total of 14 assurance standards

Furthermore, there has been a steep increase in companies, and some public agencies, issuing sustainability reports based on the GRI G3 Guidelines published in 2006. This is a result of ten governments formally referencing GRI in their governmental corporate responsibility guidance documents and/or policies. The European Union, the United States, Denmark, Sweden, Spain, France, India, South Africa, China and Canada have all mandated sustainability reporting. GRI hosts the Report or Explain Campaign Forum, a convening space for those wanting to drive sustainability disclosure through a global policy framework that requires companies to report their sustainability performance or explain why they do not. As investors increasingly demand sustainability performance information, GRI also participates in the Corporate Sustainability 6 Reporting Coalition, led by AVIVA, and the Green Economy Coalition . In response to the United Nations Conference on Sustainability Development (Rio+20, held in June 2012) the governments of Brazil, Denmark, France and South Africa joined together in a political coalition, ‘The Group of Friends of Paragraph 47’, to advance corporate sustainability reporting. With the technical advice and support of UNEP and GRI, the ‘Group of Friends of Paragraph 47’ will investigate possible ways for advancing best practices and governmental action on corporate sustainability reporting, and for developing capacity in

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KPMG. KPMG International Survey of Corporate Responsibility Reporting, 2010. http://www.kpmg.com/au/en/issuesandinsights/articlespublications/pages/kpmg-international-survey-corporate-responsibility-reporting-2011.aspx 5 UNEP, GRI, KPMG, University of Stellenbosch Business School, Carrots and Sticks - Promoting Transparency and Sustainability, 2010. https://www.globalreporting.org/resourcelibrary/Carrots-And-Sticks-Promoting-Transparency-And-Sustainbability.pdf 6

The Green Economy Coalition (GEC) is a diverse set of organisations and sectors from NGOs, research institutes, UN organisations, business to trade unions who have come together to recognise that the economy is failing to deliver either environmental sustainability or social equity. http://www.greeneconomycoalition.org. PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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developing countries. The members of the ‘Group of Friends of Paragraph 47’ have come together with the ambition to build on what already exists in terms of policy and practice, and to construct models for best practice guidance and policy, as an inspiration for other countries.

Sustainability reporting and the public sector International trends in public sector sustainability reporting 7

In 2010 GRI carried out research into public sector reporting. The publication GRI Research on Public Agencies Reporting and 8 general Information about GRI and public agency reporting can be found in the Pilot Public Agency Sector Supplement (2004) . The UK government Department of Environment, Food and Rural Affairs (DEFRA) has also produced specific guidance on 9 sustainability reporting for public agencies: Public Sector Annual Reports: Sustainability Reporting Guidance for 2011-12 . As part of its Greening Government Commitment and Sustainable Development Strategy, the UK government encourages both companies and public bodies to disclose their sustainability and environmental performance via their annual reports and accounts. Other governments incentivising public sector reporting includes those of Sweden, Germany and the United States. The Swedish government mandates GRI sustainability reporting for state-owned companies. The German government‘s Action Plan for Corporate Social Responsibility promotes reporting by German ministries, and the Ministry of Social and Labor Affairs has committed to publishing its first GRI report. The German government’s Plan states, “Individual federal ministries will issue informative CSR reports, in keeping with their role as models and pacemakers in the area of social responsibility.” Public agency reporting in the US is becoming more and more prominent because of government policy. In October 2009, 10 President Obama created a landmark for sustainability in the US with his Executive Order . The Executive Order sets out sustainability goals for federal agencies to make improvements in their environmental, energy and economic performance. It requires Federal Agencies to set a 2020 greenhouse gas emissions reduction target within 90 days; increase energy efficiency; and leverage Federal purchasing power to promote environmentally-responsible products and technologies. The Order also asks agencies to reduce their petroleum use by 30 percent and to improve water efficiency by 26 percent by 2020, and requires 95 percent of all contracts to meet sustainability requirements. 11

The European Commission recently published its A Renewed EU strategy 2011-14 for Corporate Social Responsibility that also encourages public authorities to take steps to improve disclosure of their own social and environmental performance. This has been reinforced by EU member states, including the German government as indicated above.

Domestic trends in public sector sustainability reporting Despite the global growth in reporting only a handful of public sector agencies in Australia have made a commitment to sustainability reporting and GRI. There are some organisations in Australia undertaking sustainability reporting, but at the time of publishing this paper none of the state or territory governments in Australia had adopted sustainability reporting as a policy. The Australian Government is currently investigating this possibility. The Department of Finance and Deregulation is developing advice on the adoption of a sustainability reporting framework for Australian Government agencies.

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GRI Research on Public Agencies Reporting - https://www.globalreportinig.org/resourcelibrary/GRI-Reporting-in-Government

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Pilot Public Agency Sector Supplement - https://www.globalreporting.org/reporting/sector-guidance/pilot-versions/publicagency/Pages/default.aspx 9

http://www.hm-treasury.gov.uk/frem_sustainability.htm

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Following this Executive Order, Federal agencies have started to track their sustainability performance using the GRI Framework, and have also sought ways in which to ‘green’ their procurement policies. The US Army and the US Postal Service have both issued sustainability reports, the US General Services Administration has been internally trained by one of GRI‟s Certified Training partners, and the US Airforce has issued a report on how to manage their „operational sustainability‟. 11

European Commission, A renewed EU strategy 2011-14 for Corporate Social Responsibility, 2010. http://ec.europa.eu/enterprise/newsroom/cf/_getdocument.cfm?doc_id=7010 PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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Just some of the government owned enterprises and agencies reporting with GRI’s Guidelines in recent years include ABC, Aurora Energy, Ausgrid, Australia Post, City West Water, Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA), Department of Sustainability and the Environment, Eraring Energy, Ergon Energy, GMW Water Corporation, Hydro Tasmania, Judicial Commission of NSW, Landcom, Mainroads Western Australia, Melbourne City Council Penrith City Council, South East Water, Sydney Water Corporation, the Water Corporation and Yarra Valley Water. The experiences of these agencies have been pivotal research for this work. These agencies have demonstrated and discovered value in sustainability reporting. There are opportunities for many other jurisdictions and public sector agencies to follow suit.

Why should the public sector undertake sustainability reporting? Australian public sector organisations are facing an ever-growing demand from different stakeholders to be more transparent and accountable about their economic, environmental and social performance. However, there is a vast array of required reporting from public sector organisations, much by central agencies, which can become a significant burden for agencies, especially when it is not integrated into operational management information and reporting systems. Central agencies and other parties often require similar information. There is recognition that there is a need for an overall information model where minimum data sets are defined for each area of required performance reporting (services, people, economic and corporate) and which is aligned with management reporting at the agency, central and public levels. Information ideally should be collected once and used many times and derived from departmental operating systems so that is then seamlessly used for public reporting purposes. All this requires common definition and standardisation. Sustainability reporting can play a crucial role for Australian public sector agencies in enabling transparency and accountability, while streamlining reporting processes. It is not about adding more information for public reporting; it’s about making the connections and encouraging holistic thinking. This can have the benefit of removing the clutter and reducing the reporting burden. Sustainability reporting can add value and quality to management information in the public sector, ensuring that pivotal performance information is disclosed. Sustainability measurement and reporting can play an important role in that ‘what gets measured gets done’. The existence of sustainability metrics can assist in making sustainability issues an integral part of decision-making processes within the public sector. Sustainability reporting can also assist organisations in a variety of existing reporting and management tasks, such as strategic planning, operational efficiency, customer service, stakeholder management, labour relations, workforce management and environmental management. There is potential to align much of the public reporting required by agencies with GRI’s disclosure items. Sustainability reporting can provide the bridge amongst the various disclosures depicted in Figure 1. GRI’s Sustainability Reporting Framework can also help organisations understand the linkages between operational impacts, government policies or strategies, and outcomes.

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Figure 1: Government information management hierarchy - potential alignment with GRI

(Adapted from: NSW Commission of Audit Report, 201212)

Generally, public sector reporting that relates to sustainability disclosure can be classified into three distinct categories: • • •

reports such as annual reports that cover the overall performance of an agency reports of policy or strategies, such as an environment plan or sustainability strategy reports that present the conditions of a geographical area (country, state, region, city or local government area) such as a State of the Environment Report (SoER)

As a sustainability report seeks to describe the impacts of an organisation and its activities, the first category has most application to sustainability reporting and the other two categories can provide some relevant information. Whilst it is often assumed that sustainability reporting and state of the environment reporting are synonymous, it is important to understand that the SoER rarely provides information or data which will inform how any individual public agency’s own performance affects the environment. This is illustrated in the mapping analysis in the accompanying document: Public Sector Reporting and GRI Alignment Matrix.

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NSW Government. NSW Commission of Audit 2012, 2010., www.treasury.nsw.gov.au PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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Understanding Sustainability Reporting GRI’s Sustainability Reporting Framework GRI’s Sustainability Reporting Framework consists of the Sustainability Reporting Guidelines, Sector Supplements, National Annexes, and the Boundary and Technical Protocols. The Sustainability Reporting Framework is intended to serve as a generally accepted framework for reporting on an organisation’s economic, environmental, and social performance. It is designed for use by organisations of any size, sector, or location. It takes into account the practical considerations faced by a diverse range of organisations – from small enterprises to those with extensive and geographically dispersed operations. The Sustainability Reporting Framework is developed using a process that seeks consensus through dialogue between stakeholders from business, the investor community, labour, civil society, accounting, academia, and others. The Sustainability Reporting Guidelines are the foundation of GRI’s Framework and are now in their third generation. They feature sustainability disclosures that organisations can adopt flexibly and incrementally, enabling them to be transparent about their performance in key sustainability areas. The G3.1 Sustainability Reporting Guidelines are the latest and most complete version. Launched in 2011, G3.1 completes the content of the G3 Guidelines released in 2006. G3.1 features expanded guidance on local community impacts, human rights and gender. The fourth generation of Guidelines – G4 – is currently in development, and will be launched in May 2013.

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Orientation to the GRI Sustainability Reporting Guidelines The Sustainability Reporting Guidelines consist of Reporting Principles, Reporting Guidance, and Standard Disclosures (including Profile Disclosures and Performance Indicators) (See Figure 2). These elements are considered to be of equal in weight and importance. Figure 2: Overview of GRI Sustainability Reporting Guidelines

Content

Quality

Reporting Principles and Guidance To ensure a balanced and reasonable presentation of the organisation’s performance, a determination must be made about what content the report should cover. This determination should be made by considering both the organisation’s purpose and experience, and the reasonable expectations and interests of the organisation’s stakeholders. Both are important reference points when deciding what to include in the report. It is not the expectation of GRI that all reporting organisations report against all indicators and standard disclosure, rather an organisation will select that which is most relevant to their organisation and audience. Main elements of the reporting process facilitated by GRI’s guidance include:

• The Reporting Principles of Materiality, Stakeholder Inclusiveness, Sustainability Context, and Completeness, help determine what to report. Application of these Principles with the Standard Disclosures determines the topics and Indicators to be reported

• The Reporting Principles of Balance, Comparability, Accuracy, Timeliness, Reliability, and Clarity, help achieve the appropriate quality of the reported information PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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• Guidance for reporting organisations on how to define the range of entities represented by the report, also called the ‘Report Boundary’

Standard Disclosures The Guidelines identify information that is relevant and material to most organisations and of interest to most stakeholders for reporting the three types of Standard Disclosures:

• Strategy and Profile: Disclosures that set the overall context for understanding organisational performance such as its strategy, profile, and governance

• Management Approach: Disclosures that cover how an organisation addresses a given set of topics in order to provide context for understanding performance in a specific area

• Performance Indicators: Indicators that elicit comparable information on the economic, environmental, and social performance of the organisation

The importance of Materiality While all the Principles of GRI’s Sustainability Reporting Framework are of equal importance, understanding the Principle of Materiality in the context of this paper is particularly important. This paper sets out to map existing public sector reporting requirements against all of GRI’s disclosures. However, it is not necessary for a single agency or department to report against all disclosures. Instead, by following GRI’s Principles, including its Materiality Principle, an agency can report against as few as ten Performance Indicators that are critical to the success of the organisation. Definition of materiality: The information in a report should cover topics and indicators that:

• reflect the organisation’s significant economic, environmental, and social impacts or • would substantively influence the assessments and decisions of stakeholders Public sector organisations are faced with a wide range of topics on which they could report. Relevant topics and indicators are those that may reasonably be considered important for reflecting the organisation’s economic, environmental, and social impacts, or influencing the decisions of stakeholders, and, therefore, potentially merit inclusion in the report. Materiality is the threshold at which topics or indicators become sufficiently important that they should be reported. Beyond this threshold, not all material topics will be of equal importance and the emphasis within a report should reflect the relative priority of these material topics and Indicators.

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Preparing for Integrated Reporting

Figure 3: IIRC's Overarching Framework

The recent global financial crisis has called into question traditional approaches to business decision making that focus on short-term profits over long-term sustainability. Financial reporting has failed to provide an accurate view of an organisation’s operations or the social, environmental and economic context within which it operates. However, sustainability reports do consider these factors. With this in mind, in 2010 the Global Reporting Initiative, the Prince of Wales’s Accounting for Sustainability, and the International Federation of Accountants 13 established the International Integrated Reporting Council (IIRC) . The ambition was to develop an integrated reporting framework that will facilitate the development of integrated financial and non-financial reporting over the st 14 coming decades to meet the needs of the 21 Century . The IIRC is now an independent organisation with a membership of world leaders from corporate, investment, accounting, securities, regulatory, academic, civil society and standard-setting sectors. The IIRC’s Integrated Reporting Framework will help ensure an internationally consistent approach to reporting that brings together material information on both financial and non-financial performance. The IR framework will aim to bring together the disparate disclosure requirements of regulators, markets and civil society into a coherent, integrated whole, thereby seeking to reduce the reporting burden. It will initially be focused on the investment sector and listed companies. Integrated reporting aims to be considerably more concise and connected that traditional business reporting which has included separate standalone reports for financial performance, governance and remuneration, sustainability performance and management commentary. Instead the emphasis is on the linkages between financial and non-financial information, between past and current performance, and between current performance and future outlook. The IIRC’s Integrated Reporting Framework aims to be of use in informing the reporting process, but not to provide a full reporting standard or guidelines. In financial and integrated reporting terms, a framework is a high-level paper that sets out the concepts and principles underlying corporate reporting (See Figure 3). For the framework to provide complete guidance, it would need to be used alongside financial reporting standards and sustainability reporting guidelines. Reporting standards, such as IASB’s International Financial Reporting Standards (IFRS) or country-specific Generally Accepted Accounting Principles (GAAP), provide the IIRC with high quality guidance for financial reporting. These financial reporting standards must be matched by sustainability reporting guidance that is equally trustworthy. As pioneers of sustainability reporting, able to draw on the skills and experience of its multi-stakeholder network, GRI can provide the trustworthiness that integrated reporters will need. 15

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A Discussion Paper has been released by the IIRC and an international Pilot Program , which includes a business network involving Stockland, bankmecu and NAB, as well as an investor network involving AMP Capital Investors, Australian Council of Superannuation Investors, Colonial First State Global Asset Management and Victorian Funds Management Corporation, has commenced. An internationally accepted definition for integrated reporting is expected to be released by the IIRC at the end of 2012, and an agreed upon framework is expected at the end of 2013.

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IIRC members include: International Organisation of Securities Commissions, International Accounting Standards Board, International Federation of Accountants, Financial Accounting Standards Board, ACCA, CPA Australia, Global Accounting Alliance, World Business Council for Sustainable Development, Climate Disclosure Standards Board, 100 Group of Finance Directors, International Corporate Governance Network, Tokyo Stock Exchange Group, Inc, UNEP Finance Initiative, UN Global Compact, UNCTAD’s ISAR, Ernst & Young, KPMG International, PricewaterhouseCoopers International Limited, Deloitte Touche Tohmatsu, Grant Thornton International, WWF International, Transparency International, BDO International, Natura, HSBC, WEF, Nestle, CIMA, EDF Group, APG, Volans, Tata, Universidade de São Paulo, Harvard Business School 14

IIRC draft framework builds upon the work of The Prince’s Accounting for Sustainability Project, the Global Reporting Initiative, the World Business Council for Sustainable Development, the World Resources Institute, the World Intellectual Capital Initiative, the Carbon Disclosure Project, the Climate Disclosure Standards Board, the European Federation of Financial Analysts, the United Nations (UN) Conference on Trade and Development, the UN Global Compact, the International Corporate Governance Network, the Collaborative Venture on Valuing Non-Financial Performance etc.,. 15

International Integrated Reporting Council, Towards Integrated Reporting – Communicating Value in the 21st Century, 2011. www.theirc.org.

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http://www.theiirc.org/companies-and-investors/ PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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Some national governments are introducing sustainability reporting requirements ahead of others and in some cases countries have already introduced integrated reporting. In a world first, the Johannesburg Stock Exchange introduced a listing 17 requirement for companies to ‘prepare or publicly explain’ why they have not prepared an integrated report . GRI is currently developing the next generation of its Guidelines (G4). Key to its on-going improvement is that the Guidelines provide companies with guidance on integrated reporting and, in the context of the IIRC’s framework, to help users formulate content for integrated reports. The G4 Guidelines are scheduled for release in May 2013. Given the role of public agencies in delivering value beyond financial value (that is ecological and societal value also), it is logical that integrated reporting could also be applied by public agencies as it matures internationally.

Mapping GRI against public sector reporting requirements Methodology – mapping reporting frameworks This paper maps current reporting requirements for Australian public sector agencies against the GRI G3.1 Sustainability Reporting Guidelines (See Tables 1 and 2). Given the range of different public sector agencies and variances in reporting requirements, an in-depth mapping of NSW public reporting requirements has been undertaken, referencing a couple of representative NSW agencies. The NSW public sector includes departments, declared authorities, state-owned corporations, health services and universities. This report has concentrated on departments (specifically NSW Health) and declared authorities (specifically Sydney Water Corporation). All are referred to as public sector agencies throughout this paper. The results of Manidis Robert’s desktop survey and review of public sector sustainability reporting activity by Australian Government agencies has also been included. Public sector reporting requirements The research began by investigating the reporting requirements that are applicable across government departments and agencies and which are generated by either State or Federal legislation, taking NSW as a case study. Particular attention was given to the annual (including Schedules) environmental and sustainability reporting requirements relevant to the NSW public sector. When reviewing Annual Reporting the Schedules attached to these reports were included. Figure 4: Suite of sustainability disclosures currently required in NSW

SOE report

NGERS Report

Annual Report POEO Report

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EEO Report

Sustainability (Waste reduction) Policy Report

Framework For Integrated Reporting and the Integrated report Discussion Paper 25 January 2011, IRCSA PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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The analysis included review of the following:

• Annual Report Compliance Checklist – annual reporting requirements outlined in NSW Treasury Guidelines (2011) (NSW Treasury, 2011)

• The Energy Efficiencies Opportunity Act 2006 • National Greenhouse and Energy Reporting (NGERS) • The NSW State of the Environment Report • The NSW Sustainability Policy including the NSW Waste Reduction and Purchasing Policy • Environmental Protection Licences (POEO Act)

This list does not include reporting requirements that are specific to individual agencies or the full array of reporting to the Australian Government (which includes service delivery, human resources, financial management, asset management, procurement, and other statutory and compliance data). However, the research did examine the additional reporting requirements of a couple of government departments. The above collection of reporting requirements provides a snapshot of public reporting that all NSW agencies have to currently undertake which can be mapped against GRI disclosures as seen in the accompanying document: Public Sector Reporting and GRI Alignment Matrix. It should be noted that in addition to the above reporting requirements, departments are also bound to a legislated set of core values, which are implemented through Codes of Conduct and Ethics in each organisation. NSW Government public servants are expected to abide by the standards of conduct contained in the Code of Conduct issued by the Premier’s Department. In addition, there are general laws that cover employees’ and organisations’ respect for law and the systems of government, such as the Public Sector Employment & Management Act 2002 and Protected Disclosures Act 1994 (governing conduct of staff members, complaints and disciplinary matters), as well as anti-discrimination legislation and policies, and public finance and audit legislation and delegations (covering purchasing goods or services). All of these relate to some of the elements of sustainability reporting. The translation of these into meaningful processes, including reporting for each of the NSW organisations that were studied, has not been covered in this first analysis.

Mapping process Both sets of themes and indicators – from NSW Annual Reporting (plus other required sustainability reporting) and GRI - were mapped to assess whether information gathered as part of reporting requirements could, either directly or with some modification, be used to report with GRI. This mapping was checked against the annual reports of two government agencies: Sydney Water Corporation and NSW Health. These organisations were chosen as they were judged to provide different aspects of the work of government. Each organisation is subject to additional reporting requirements related to their constitution, purpose and nature of work, which in turn could provide further information to respond to GRI disclosures. This mapping was then analysed to provide a picture of overlap between all the reporting requirements as well as an indication of possible modifications to bring existing reporting requirements more into line with GRI reporting. The accompanying document: Public Sector Reporting and GRI Alignment Matrix contains the full mapping exercise and the public sector and GRI disclosure descriptions and modifications. Summary analysis is contained below in Table 1: Summary of mapping results and Table 2: Public Sector reporting against the GRI Sustainability Reporting Framework (Appendix A).

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GRI’s G3.1 disclosures under the spotlight As stated in Section 2.0 above, GRI’s Sustainability Reporting Framework offers much more than just indicators. However, for the purposes of demonstrating current alignments with current NSW Government reporting requirements, this mapping exercise focuses only on GRI’s Sustainability Aspects – the GRI term for specific issues and topics - and 126 disclosure items (see GRI Sustainability Reporting Guidelines G3.1 – Reference Sheet).

Mapping results – public agency reporting and GRI The analysis determined that of the 126 GRI disclosure items, 66 could potentially be answered, either directly (25) or partially (6), from general mandatory data, and/or with some modification using information and data from existing reporting requirements (35). A further 29 disclosures could potentially be answered using readily available corporate information. Thirtyone (31) GRI disclosures could not be readily answered using existing cross-government reporting requirements. Summary of mapping results Number of GRI disclosure items

126

Total disclosures that can be directly answered from general mandatory reporting data

25

20%

Total disclosures that can be answered, partly or wholly, from general mandatory reporting data with some modification in data gathering

35

28%

Total disclosures that could be easily answered from corporate information

29

23%

Total disclosures that can be directly answered, only partly, from general mandatory reporting data

6

5%

Number of disclosures not currently addressed by government reporting

31

25%

However, this gap closes for the two case example departments, when specific department-focussed reporting requirements were also mapped against GRI. For example, many of the Environment Performance Indicators in GRI could be, and are, completed by Sydney Water using data gathered to report on compliance with its Operating Licence. Equally, reporting by NSW Health against success targets in the State Health Plan could be used for some of the GRI disclosures, as shown in Appendix A. Table 2 sets out the GRI disclosures against topics and elements to illustrate the areas of alignment (Appendix A). Some of the disclosures where there is currently no comparable reporting could be covered from corporate information but this should not be assumed to be the case for all agencies. These areas include: biodiversity; human rights; society; product responsibility and economic performance. This is not to say that organisations do not report or gather data in these areas. However the information gathered does not appear to be in a format that could be directly applied to GRI reporting even with some modification. For example, State of the Environment reporting (carried out every three years) compiles a lot of data on biodiversity (Australian Public Services Commission, 2011). However it tends to focus on the distribution and presence of threatened or invasive species in a geographical area. GRI biodiversity Performance Indicators, by contrast, focus on an organisation’s operational impacts on biodiversity and associated mitigation measures. These findings are consistent with the Australian Government Department of Finance and Deregulation’s desktop survey and other recent research in the sector. The Australian Government is currently developing advice on the adoption of a sustainability reporting framework for Australian Government agencies. As part of this process the Department of Finance and Deregulation (DFAD) has undertaken a desktop survey and review of public sector sustainability reporting activity. DFAD’s desktop survey has found that the Australian Government already collects and reports significant amounts of sustainability data and information,

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18

much of which aligns with GRI and other sustainability reporting framework requirements. Data can be sourced from agency Annual Reports, the State of the Services Report and the Energy Use in Australian Government Operations report. It should be noted that by requiring an assessment of the materiality of issues, the GRI Sustainability Reporting Framework provides a focus on the most important sustainability issues and indicators. A public sector agency would not be required to report on all 126 GRI disclosures. In fact, central government agencies could offer guidance on a limited number of key 18 materiality topics agencies and departments should consider reporting , thereby also giving flexibility to government departments and agencies to add additional topics and indicators relevant to their organisation. See Section 3.1 for further guidance. Reviews of reporting amongst public sector agencies have shown that the application of GRI disclosures is fragmented and even 19 though almost all reporters state that they are following GRI, many are unfortunately cherry-picking indicators (Guthrie, 2008) . They are not reporting all the core and sector-specific Performance Indicators included in the GRI Sustainability Reporting Framework and this filtering is not necessarily guided by materiality. The most reported Indicators include those for labour practices and environment performance. The least reported are those for society, product responsibility and human rights. This suggests that there would be difficulties accessing data related to these later sustainability themes, and that critical areas of sustainability are being overlooked by organisations. It goes without saying that good tools need well-trained people and that to a large extent the successful use of the GRI Sustainability Reporting Framework will depend upon intention, motivation and the care taken in its use. Much of the governance, labour and environment reporting areas in GRI could be completed with existing reporting data, but only with modification in the way that data is collated and gathered. In some cases the modification would be significant and could require a complete rethinking of the data collation rationale and process. The extent of this modification is clearly a topic for further investigation. For example, completing GRI governance disclosures requires only a change in the way an organisation ‘tells the story’ of its operations and structure in its annual report. By comparison, GRI Labour Performance Indicators require the collection, year on year, of specific statistics and data. If undertaken effectively, agencies could collect data in a way that could then be ‘cut’ for numerous reporting requirements. This could then contribute greatly to the NSW Government aim to streamline and reduce the reporting burden.

18

see GRI Sustainability Reporting Guidelines G3.1 – Reference Sheet

19

Guthrie, J. & Farneti, F., ‘GRI Sustainability Reporting by Australian Public Sector Organizations’, Public Money & Management, Volume 28, Issue 6, 2008: pages 361-366 PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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Table 1

Public sector reporting against the GRI Framework

GRI Aspects

GRI disclosures not currently addressed in public sector reporting

Report Parameters Various aspects of the approach to the report and the reporting parameters.

No specific gaps as the majority of these Aspects are set by the reporting entity itself.

Governance, commitments & engagements Various aspects of organisational governance.

No specific gaps as the majority of these Aspects relate to a description of the reporting entity itself – much of this information would be available in corporate information. There are some areas that may be new to the organisation including: Profile Disclosure 4.12 Externally developed, economic, environmental and social charter, principles or initiatives to which the organisation subscribes and/or endorses.

Environment PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

Materials (EN1, EN2) Energy (EN3, EN4, EN5, EN6, EN7) Water (EN8, EN9, EN10)

• EN11 to EN15 All biodiversity Performance Indicators. • EN25 Identity, size, protected status and biodiversity value of water bodies and related habitats significantly affected by the reporting organisation’s discharges of water and runoff.

Biodiversity (EN11, EN12, ENEN13, EN14, EN15) Emissions, effluents & waste (EN16, EN17, EN18, EN19, EN20, EN21, EN22, EN23, EN24, EN25) Products/Services Products and Services (EN26, EN27)

EN27 – Percentage of products sold and packaging materials reclaimed – no data on products.

Compliance Compliance (EN28)

Data could be compiled for this Performance Indicator.

Transport Transport (EN29)

• EN29 – Environmental impacts of transporting products, goods and…workforce – no data on transport impacts.

Overall Overall (EN30)

Data on expenditure could be compiled for this Performance Indicator.

20

Human rights Investment & Procurement Practices (HR1, HR2, HR3)

• HR1 to HR11 – all Performance Indicators. There is not equivalent data readily available.

Non Discrimination Practices (HR4) Freedom of association & collective bargaining (HR5) Child labour (HR6) Forced & compulsory labour (HR7) Security practices (HR8) Indigenous rights (HR9) Assessment (HR10) Remediation (HR11) PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

Labor practices Employment (LA1, LA2, LA3)

No gaps – all current data could be modified.

Labor/management relations (LA4, LA5) Occupational Health & Safety (LA6, LA7, LA8, LA9) Training and Education (LA10, LA11, LA12) Diversity & Equal Opportunity (LA13, LA14) Society Community (SO1) Corruption (SO2, SO3, SO4) Public policy (SO5, SO6)

• SO3 – Percentage and total number of business units analysed for risks related to corruption. • SO4 – Actions taken in response to incidents of corruption. • SO7 – Anti-competitive behaviour.

Anti-competitive behaviour (SO7) Compliance (SO8) Product responsibility Customer Health & safety (PR1, PR2) Product & Service Labelling (PR3, PR4, PR5) Marketing Communications (PR6, PR7) Customer Privacy (PR8)

• PR1 – Life cycle stages in which health and safety impacts of products and services are assessed for improvement and percentage of significant products and services categories subject to such procedures.

• PR3, PR4, PR6, PR7 – Products and servicing labelling; marketing & communications.

21

Compliance (PR9)

• PR9 – Value of fines for non-compliance with products and services regulations. Little or no data specifically related to product and services impacts.

Economic Economic Performance (EC1, EC2, EC3, EC4) Market Presence (EC5, EC6, EC7)

• EC2 – Financial risks and opportunities due to climate change • EC9 – Economic performance, market presence and indirect economic impacts.

Indirect Economic Impacts (EC8, EC9) Note: XXX denotes potential gaps in data and indicators. The full mapping exercise (disclosures, descriptors and data sources) is included in the accompanying documents: Public Sector Reporting and GRI Alignment Matrix and the Public Sector and GRI Indicator Descriptions And Modifications table.

PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

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Conclusions & Next Steps More similarities than dissimilarities Public sector entities wishing to align their reporting with GRI’s Sustainability Reporting Framework will not need to start the process from scratch. What is clear is that there are more similarities than dissimilarities between the current public sector reporting requirements and the GRI Sustainability Reporting Framework. The accompanying document: Public Sector Reporting and GRI Alignment Matrix contains the full mapping exercise and the public sector and GRI disclosure descriptions and modifications. Public agencies are supported to improve their social and environmental performance by managing, measuring and reporting the impacts that organisations have on society and the environment. The mapping exercise highlights that public sector agencies are in an excellent position to transition to GRI reporting. Agencies already using the GRI Sustainability Reporting Framework are demonstrating that it is practicable to apply existing reporting expertise and data to fulfill the requirements of GRI. For other organisations, reporting with GRI will involve coordinating and harmonising existing activities, rather than building new systems and processes from the ground up. Many large organisations already have an infrastructure and processes in place to capture and report on key information. In such cases, the challenge lies in effective collaboration and synthesis.

Next steps This paper provides initial considerations to foster a greater understanding of the nature and scale of sustainability reporting requirements as compared to existing reporting requirements for the public sector. The aim is to stimulate the harmonisation with existing reporting standards for the public sector in Australia. A goal is to also improve preparedness for sustainability reporting and avoid unnecessary duplication in reporting in the public sector. This high level assessment of reporting synergies is the first step towards the longer-term goal of providing robust and useful guidance on public sector reporting. GRI Focal Point Australia will continue to work to fulfil its Australian GRI Conference commitments in tandem with other key parties, including:

• Encouraging governments at all levels to lead by example and report to GRI – local, state, federal • Encourage governments to require government reports to follow a minimum set of sustainability disclosures

• Encourage the Council of Australian Governments (COAG) to adopt a common sustainability reporting framework for the public sector in Australia

Appendix A: Table 2 - Mapping NSW public sector reporting against GRI disclosures

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72

73

Total indicators that can be directly answered, partly or wholly, 74 from general mandatory reporting data Total indicators that can be answered, partly or wholly, from general mandatory reporting data with some modification in data 75 gathering Total indicators that could be easily answered from corporate 76 information Number of gaps 77 78

PUBLIC SECTOR SUSTAINABILITY REPORTING: REMOVE THE CLUTTER, REDUCE THE BURDEN SEPTEMBER 2012

Readily available corporate information New requirment but possible Results Number of GRI indicators

30

0

58

79

Case example agencies

80 81 82 83 84 85 86 87 88 89 90 91 Department of Health (report against the State Health Plan 2011) SD1 Increased participation and integration in community activities…. SD2 Increased customer satisfaction with health services SD6 (targets being developed) SD7 Implement integrated risk management framework in Health Services 2.4 Location of organisation's headquarters

2.5 Number of countries where the organisation operates…..

2.6 Nature of ownership and legal form

2.7 Markets served

2.8 Scale of the reporting organisation

2.9 Significant changes during the reporting period….

2.10 Awards received in reporting period

3.1 Reporting period

3.2 Date of most recent previous report

3.3 Reporting cycle

3.4 Contact point for questions regarding the report

3.5 Process for defining report content

3.6 Boundary of the report

3.7 State any specific limitations on the scope of the report

3.8 Basis for reporting on joint ventures, partially owned subsidiaries……

3.9 Data measurement techniques and the basis of calculations…

3.10 Explanations of the nature and effect of any restatements of information….

1 D

Annual reporting requirements Charter Aims and objectives Access Management and structure Summary review of operations Funds to non-government community organisations Management and activities Human resources Equal Employment opportunity Disability plans Land disposal Promotion Consumer response Payments of accounts Risk management and insurance activities Internal audit and risk management policy attestation Disclosure of controlled entities Disclosure of subsidiaries Multicultural policies and services program Agreements with the community relations commission Occupational Health and Safety (3) Waste Financial statements Identification of audited financial statements Inclusion of unaudited financial statements Additional matters for inclusion in annual reports Investment performance Liability management performance Performance and numbers of executive officers Form of annual reports - generally E F

Total indicators that can be directly answered, partly or wholly, 92 from general mandatory reporting data Total indicators that can be answered, partly or wholly, from general mandatory reporting data with some modification in data 93 gathering 94 95 (1) Indicators have been amedned for brevity 96 (2) Reporting requirements with no application to GRI have not been listed 97 (3) Incorporates reporting requirements for the government's Waste Reduction and Purchasing Policy 98 (4) Rreported under 'waste' in annual reporting above 99 (5) Conditions will vary depending on the organisation 100 (6) Reports against success targets under 7 strategic directions. Only relevant targets are listed here. 101 102 103 D- Direct applicability of indicator 104 M- Modification of indicator needed 105 C - Corporate information available to support indicator 106 P- Partial coverage of indicator 107 G- Gap (no relevant indicator or data) 108 109 G

D D D D

H I

GRI indicator

J K L (1)

M

D D D D D D D D D D

D D D D

D D D D

C

N O P Q R S

D

T U V W X

1.10 1.20 2.10 2.10 2.30 2.40 2.50 2.60 2.70 2.80 2.90 2.20 3.10 3.20 3.30 3.40 3.50 3.60 3.70 3.80 3.90 3.10

4.1 Governance structure of the organisation

4.2 Chair of the highest governance body is also an executive officer

4.3 No of members of the highest governance body that are independent….

4.4 Ways for shareholders and employees to recommend to highest governance body

4.5 Link between compensation and performance for highest governance body

4.6 Process of the governance body to avoid ensure conflicts of interest

4.7 Process for determining qualifications and expertise of the highest governance body

AJ

3.13 Policy and practice for seeking external assurance for the report

4.8 Internally developed mission codes of conduct and value statements

4.9 Process for highest governing body to oversee organisation's performance

4.10 Process for evaluating the performance of the highest governance body

4.11 Whether and how precautionary principle is addressed by organisation

4.12 Externally developed principles….

4.13 significant memberships in associations

4.14 List of stakeholder groups engaged by the organisation

4.15 Basis for identification and selection of stakeholders to engage

4.16 Approaches to and frequency of stakeholder engagement

4.17 Key issues and concerns raised through stakeholder engagement…..

EN1 materials used by weight or volume EN2 Percentage of materials used that are recycled input materials EN3 Direct energy consumption by primary energy source EN4 Indirect energy consumption by primary source EN5 Energy saved due to conservation and efficiency improvements EN6 Initiatives to provide energy-efficient / renewable energy products…. EN7 Initiatives to reduce indirect energy consumption and reductions achieved EN8 Total water withdrawal by source EN9 Water sources significantly affected by withdrawal of water EN10 percentage and total volume of water recycled and reused EN11 Land owned, leased, managed in, or adjacent to protected areas…. EN12 Description of significant impacts….on biodiversity EN13 Habitats protected or restored EN14 strategies, actions and plans for managing Impacts on biodiversity EN15 Number of IUCN red list species…in areas affected by operations…. EN16 Total direct and indirect greenhouse gas emissions by weight EN17 Other relevant indirect greenhouse gas emissions by weight EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved EN19 Emissions of ozone-depleting substances by weight EN20 Nitrogen oxides and sulpher oxides and other air emissions EN21 total water discharge by quality and destination EN22 total weight of waste by type and disposal method EN23 total number and volume of significant spills EN24 weight of transported, exported or treated waste deemed hazardous….. EN25 identity, size, protected status and biodiversity value of water bodies…. EN 26 Initiatives to mitigate environmental impacts of products EN27 Percentage of products sold and packaging materials reclaimed EN28 Value of fines…for non-compliance with environmental laws and regs EN29 Environmental impacts of transporting products, goods and…workforce

Z

3.12 GRI content index …..

Y

3.11 Significant changes from previous reporting period …..

2.3 Organisational structure

Reporting requirement with some (2) application to GRI 2.2 Major brands, products or services, including volume

C

2.1 Name of the reporting organisation

B

1.2 Description of key risks and opportunities

A

1.1 Statement from chief executive officer and chair

AA

3.11 3.12 4.10 4.20 4.30 4.40 4.50 4.60 4.70 4.80 4.90 4.10 4.11 4.12 4.13 4.14 4.15 4.16 4.17 E1 E2 E3 E4 E5 E6 E7 E8 E9 E10 E11 E12 E13 E14 E15 E16 E17 E18 E19 E20 E21 E22 E23 E23 E25 E26 E27 E28 E29

AB

C C C C C C C C C C C C C C C

AC AD AE AF AG AH AI

M M M M M M M M

AK

Sydney Water (report against its Operating Licence 2010-2015) 4 Customer and consumer rights 5 Complaint and dispute handling 6 Environment indicators and management 7 Water conservation

0

0

AL

D D

AO

D D

AP

D D

AQ

D D

AR

D D

AS

C C C C C C

AT

M M

M

D

AU

Energy Efficiencies Opportunity Act 2006 Energy use for the Whole Corporate Group Information on energy assessed Business response to opportunities assessed Cost of assessment Cost of compliance Opportunities not implemented Individual opportunities by type

National Greenhouse and Energy Reporting (using OSCAR) Energy use GHG

NSW Sustainability Policy reporting (using OSCAR) Energy consumption Water consumption NABERS rating Waste Reduction and Purchasing(4) Car fleet

State of the Environment report People and the Environment Climate Change Human Settlement Atmosphere Land Water Biodiversity

D

AV

D D

D D

M

AW

D D

P M

D D

M M

M M

P P

M

AX

M

AY

M

AZ

P P

D D D

D D D

M

BA

Environmental protection licences (5) Compliance with licence conditions Complaints BB

P

P

BC

P P

D D

BD BE

M

BF

D

BG

D

BH

D D

M

BI

D

BJ

D

BK

P D D D D D D

M M M

M M M

P P

M

BL

P

M

BM BN

M

P

D

BO

M

M

BP

M

D

BQ BR

M

BS

M

M

BT

P

BU

D

D D D

CB CC CD CE CF CG CH CI

E30 HR1 HR2 HR3 HR4 HR5 HR6 HR7 HR8 HR9 HR10 HR11 LA1

D

M

M M D

D

HR2 Percentage of suppliers / contractors with human rights screening training HR3 total house of employee training on human rights HR4 total number incidents of discrimination HR5 Operations where freedom of association and collective bargaining at risk HR6 operations having significant risk of child labour HR7 Operations with risk of forced or compulsory labour HR8 percentage of security personnel trained in human rights HR9 Number of violations involving indigenous people HR10 Percentage of operations with human rights reviews / assessments HR11 Number of grievances related to human rights LA1 total workforce by employment type. Contract and region M

M M

M

CP

LA2 LA3 LA4 LA5 LA6 LA7 LA8

M D M M M M M M

M

CQ

M

CR

M

CS

M

CT

M

CU

M D M

D

6

M

CV

M D M

126

49 C D D D D D D D D D C C C C C C C C C C C C C C C M M M M D M M M M M M C C C C C C M D D D D D D D P D G G G G G D D D P P M M M M G P G P G P G G G G G G G G G G G D D M M M M M M M M M M D D

0 2 2 4 1 1 2 4 4 4 0 0 1 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 2 5 5 4 2 2 0 0 0 0 0 0 0 0 2 2 2 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 1 0 0 0 0 0 0 0 0 0 0 1 2

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 1 1 1 1 1 1 1 3 2 1 2 0 0 0 0 0 0 1 1 2 2 1 0 0 0 0 0 0 0 0 0 0 2 2 2 0 0 1 2 1 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 2 2 2 2 1 1 1 4 2

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

0 2 2 4 1 1 2 4 4 4 0 0 1 0 0 1 1 0 0 1 0 0 0 0 0 1 1 1 1 2 1 1 3 2 1 2 0 0 0 0 0 1 1 3 7 7 5 2 2 0 0 0 0 0 0 0 0 4 4 4 1 0 1 2 1 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 2 1 1 1 2 2 2 2 1 1 1 5 4

LA15 Return to work and retention rates…

CO

LA14 Ratio of salary of men to women

CN

LA13 Composition of governance bodies and employees by category

CM

LA12 Percentage of employees receiving regular performance reviews…

CL

LA11 Programs for skills management and lifelong learning….

CK

LA10 Average hours of training per year…

CJ

LA9 Health and safety topics covered in agreements with unions

LA8 Education, training, counseling, prevention and risk-control programs

CA

LA7 Rates of injury, diseases, lost days and absenteeism…..

BZ

LA6 percentage of workforce represented in formal joint HSC committees….

BY

LA5 Minimum notice regarding operational changes

BX

LA4 Percentage of employees covered by collective bargaining agreements

BW

HR1 Percentage and total investments that include human rights clauses

BV

LA3 Benefits provided to full-time employees not provided to temp / part-time

M

AN

LA2 number and rate if employee turnover by age group, gender and region

M

AM

EN30 Total environmental protection expenditures..by type

Table 2 - Mapping NSW Public sector reporting against GRI indicators

CW

LA9 LA10 LA11 LA12 LA13 LA14 LA15

M

D

M D D

M M M M

D D

D D

D

P P P

P

M

DM

DN

DO

DP

DQ

PR6 programs for adhering to regs and codes regarding marketing etc…

PR7 Number of non-compliance with marketing and advertising regulations

PR 8 number of complaints regarding breaches of privacy

PR9 Value of fines for non compliance with products and services regulations

EC1 economic value generated and distributed….

EC2 financial risks and opportunities due to climate change

EC3 coverage of organisation's benefit plan obligations

EC4 financial assistance from government

EC5 range of ratio of entry level and minimum wage…

EC6 policy, practice and spend on local suppliers…

EC7 procedures for hiring local people…

EC8 investments and services primarily for public benefit…

EC9 understanding of indirect economic impacts

DC

DD

DE

DF

SO9 operations with potential for negative impacts on communities

DL

PR5 practices related to customer satisfaction including surveys…

DB

SO8 value of fines and number of sanctions for legal non-compliance

DK

PR4 Number of non-compliance with product information, labeling regulations

DA

SO7 number of legal actions for anti competitive behaviour…..

DJ

PR3 type of product and percentage of products subject to service information

CZ

SO6 value of contributions and political parties and related institutions

DI

PR2 Number of non-compliance with health and safety regs and vol codes

CY

SO5 public policy positions and participation in public policy development

DH

PR1 stages which health and safety impacts of products are assessed….

CX

SO4 actions taken in response to corruption

C

SO3 percentage of employees trained in anti-corruption policies

B

SO2 percentage of business units analysed for risk

A

SO1 percentage of operations with community engagement….programs

Table 2 - Mapping NSW Public sector reporting against GRI indicators

DG

DR

DS

DT

DU

DV

DW

DX

DY

SO1 SO2 SO3 SO4 SO5 SO6 SO7 SO8 SO9 SO10 PR1 PR2 PR3 PR4 PR5 PR6 PR7 PR8 PR9 EC1

EC2

EC3

EC4

EC5

EC6

EC7

EC8

EC9

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72

Reporting requirement with some (2) application to GRI Annual reporting requirements Charter Aims and objectives Access Management and structure Summary review of operations Funds to non-government community organisations Management and activities Human resources Equal Employment opportunity Disability plans Land disposal Promotion Consumer response Payments of accounts Risk management and insurance activities Internal audit and risk management policy attestation Disclosure of controlled entities Disclosure of subsidiaries Multicultural policies and services program Agreements with the community relations commission Occupational Health and Safety Waste(3) Financial statements Identification of audited financial statements Inclusion of unaudited financial statements Additional matters for inclusion in annual reports Investment performance Liability management performance Performance and numbers of executive officers Form of annual reports - generally

SO10 mitigation measures implemented for negative impacts on communities

1

M D M

M

M M

M M

M M

M M M M M M

M M

D M

M M

M

Energy Efficiencies Opportunity Act 2006 Energy use for the Whole Corporate Group Information on energy assessed Business response to opportunities assessed Cost of assessment Cost of compliance Opportunities not implemented Individual opportunities by type National Greenhouse and Energy Reporting (using OSCAR) Energy use GHG

NSW Sustainability Policy reporting (using OSCAR) Energy consumption Water consumption NABERS rating Waste Reduction and Purchasing(4) Car fleet State of the Environment report People and the Environment Climate Change Human Settlement Atmosphere Land Water Biodiversity Environmental protection licences (5) Compliance with licence conditions Complaints Readily available corporate information New requirment but possible Results Number of GRI indicators

C

C

C

C

M

M

G

G

C

C

G

C

C G

G

G

M

G

G

C

C G

G

C

C

C

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1

0

1

0

0

0

0

0

0

0

0

2

1

0

0

0

0

0

0

2

2

0

1

0

0

0

0

0

0

0

6

0

2

2

1

0

1

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

1

0

0

0

0

0

0

2

2

0

1

0

0

0

0

0

1

0

7

0

2

2

1

0

1

1

0

M

G

M

M

M

C

M

M

G

126

73 Total indicators that can be directly answered, partly or wholly, 74 from general mandatory reporting data Total indicators that can be answered, partly or wholly, from general mandatory reporting data with some modification in data 75 gathering Total indicators that could be easily answered from corporate 76 information Number of gaps 77 78

30

49 0 58

79

Case example agencies

80 81 82 83 84 85 86 87 88 89 90 91

Department of Health (report against the State Health Plan 2011) SD1 Increased participation and integration in community activities…. SD2 Increased customer satisfaction with health services SD6 (targets being developed) SD7 Implement integrated risk management framework in Health Services

6

Sydney Water (report against its Operating Licence 2010-2015) 4 Customer and consumer rights 5 Complaint and dispute handling 6 Environment indicators and management 7 Water conservation

M D

M M

Total indicators that can be directly answered, partly or wholly, 92 from general mandatory reporting data Total indicators that can be answered, partly or wholly, from general mandatory reporting data with some modification in data 93 gathering 94 95 (1) Indicators have been amedned for brevity 96 (2) Reporting requirements with no application to GRI have not been listed 97 (3) Incorporates reporting requirements for the government's Waste Reduction and Purchasing Policy 98 (4) Rreported under 'waste' in annual reporting above 99 (5) Conditions will vary depending on the organisation 100 (6) Reports against success targets under 7 strategic directions. Only relevant targets are listed here. 101 102 103 D- Direct applicability of indicator 104 M- Modification of indicator needed 105 C - Corporate information available to support indicator 106 P- Partial coverage of indicator 107 G- Gap (no relevant indicator or data) 108 109

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D D

D D

D D

D D

DZ

Appendix B: Table 3 - Public sector and GRI disclosure descriptions and modifications

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28

Table 3 - Public Sector and GRI indicators descriptions and modifications Reporting requirement

Legal reference Requirement

Directly applicable to GRI sections, partly or wholly

Charter

ARDR Sch.1 ARSBR Sch.1

Manner in which and purpose for which agency was established Principal legislation under which statutory body operates

Directly applicable to many indicators in Section 2 - organisational profile, in particular:

Aims and objectives

ARDR Sch.1 ARSBR Sch.1

Directly applicable to many indicators in Section 2 - organisational profile, in particular:

Access

ARDR Sch.1 ARSBR Sch.1

What agency sets out to do Range of services provided Clientele/community served Address of principal office/s Telephone number of principal office/s Business & service hours

Management and structure

ARDR Sch.1 ARSBR Sch.1

Organisation chart indicating functional responsibilities

Directly applicable to section 2.3 of the GRI requiring an organisation chart

Summary review of operations

ARDR Sch.1 ARSBR Sch.1

Narrative summary of significant operations Financial and other quantitative information for programs or operations

Much of the information used for this annual reporting requirement could be used for the organisational profile required by GRI, in particular: 2.2 major brands, products or services 2.6 nature of ownership and legal form 2.7 markets served 2.8 scale of the reporting organisation.

Name of recipient organisation Amount of grant Program area as per Budget paper Program as per Budget paper Nature & purpose of the project including aims and target clients Describe nature and range of activities Major problems and issues which arose Major works in progress, cost to date, dates of completion, significant cost overruns or delays / amendments / deferments / cancellations If practicable, qualitative and quantitative performance measures showing efficiency and effectiveness Benefits from mgt. and strategy reviews Nature and extent of internal and external performance reviews conducted and resulting improvements in achievements Management improvement plans and achievements reaching previous targets

This is directly applicable to the part of section EC1 of the GRI requesting information about " donations and other community investments"

Applicable to GRI sections with modifications, either partly or wholly

Annual reporting

Funds granted to non-government community PM 91-34 organisations ARDR Sch.1 ARSBR Sch.1

Management and activities

ARDR Sch.1

Directly applicable to: 2.4 location of organisation's headquarters 3.4 contact point for questions regarding the report This annual reporting requirement could be structured in a way that would become directly applicable to many of the indicators in section 4 of the GRI relating to the governance of an organisation With some modification in the way this information is collated, it could also be used to partly report against the economic performance indicators of the GRI in particular EC1

The information gathered to fulfill this annual reporting requirement is directly applicable to the organisational profile section of the GRI, in particular sections 2.2, 2.6, 2.7, and 2.8

The description of the management improvement processes and plans could be used to respond to 4.9 of the GRI, if structured correctly and if those processes involved the organisation's highest governing body. Data and information required to report on performance measures and achievements for this reporting requirement could be used to report against many GRI indicators, if gathered and collated in a consistent way. In particular many of the performance indicators in the environmental section of GRI could be answered from this annual reporting data.

Human resources

ARDR Sch.1 ARSBR Sch.1

Number of officers and employees by category & compare to prior three years Exceptional movements in wages, salaries or allowances Personnel policies & practices Industrial relations policies & practices

This information is directly applicable to LA1 of the GRI - total workforce by employment type, employment contract and region

Equal Employment Opportunity

TC 11/03 ARDR Sch.1

Major EEO outcomes during the reporting period accounting for planned outcomes set the previous year. Table of trends in (A) representation and (B) distribution

Directly applicable to LA2 - employee turnover; LA13 - diversity and equal The information for this reporting requirement could also be used to opportunity; and LA14 - equal renumeration for women and men. respond to GRI 4.8 which asks for an organsation's value statements or policies

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With some modification in the way HR information is gathered and collated for annual reporting purposes, it could also be used to report against most of the labour practices and decent work sections of the GRI (LA2 - LA14)

Table 3 - Public Sector and GRI indicators descriptions and modifications Reporting requirement

Legal reference Requirement

Disability Plans

PSEMA Sch. 1 DSA s9 ARDR Sch.1 ARSBR Sch.1 ARDR Sch.1 ARSBR Sch.1

Statement setting out the progress in implementing disability plan if required under the Disability Services Act 1993 (only for those required per PSEMA)

ARDR Sch.1 ARSBR Sch.1

Report on the risk management & insurance arrangements and activities affecting the agency

Internal audit and risk management policy attestation

TPP 09-5 TC 09/08

Department head / governing body of statutory must report As above compliance for the financial year with core requirements of the policy.

Disclosure of Controlled Entities

ARDR Sch.1 ARSBR Sch.1

Disclosure of Subsidiaries

PM 06-02

Multicultural Policies and Service Program (formerly EAPS)

ARDR Sch.1 ARSBR Sch.1

For each controlled entity: -Name, objectives, operations, activities -Performance targets and actual performance measures For each public sector subsidiary, the parent must: Identify each subsidiary in which shares are held, and the number and % of shares held; Include key figures for each subsidiary (turnover, profit, assets) and their proportion to group totals Include detailed statement of objectives, activities and operations of each subsidiary, performance targets and measures and accounts; and Include description of nature and extent of involvement in any other companies, joint ventures, partnerships, trusts or other such associations (whether or not incorporated) Statement setting out the key multicultural strategies proposed for the following year Progress in implementing the Department’s multicultural policies and service plan Information as to the multicultural policies and services plans of any bodies reporting to the Department

Agreements witht the Community Relations Commission

ARDR Sch.1 ARSBR Sch.1

Description of any agreement entered into with Community Relations Commission under the Community Relations Commission and Principles of Multiculturalism Act 2000 and statement setting out progress in implementing any agreement

Occupational Health and Safety

ARDR Sch.1 ARSBR Sch.1

Waste

ARDR Sch.1 ARSBR Sch.1

Statement setting out OHS performance Details of injuries and prosecutions could be directly applied to answering Details of injuries and prosecutions under Occupational Health PR2 in part. and Safety Act 2000 Statement on implementation of government’s Waste Reduction and Purchasing Policy and progress on: -Reducing generation of waste -Resource recovery -Use of recycled material This information could be used directly in reatlion to EC1 of the GRI

Consumer Response

Payment of Accounts

Time for Payment of Accounts Risk management and insurance activities

Budgets

Extent and main features of complaints Services improved/changed in response to complaints/suggestions TC 06/26 ARDR Details of performance in paying accounts for each quarter: -030, 30-60, 60-90 and 90+ $ amounts -Target %, actual % and $ Sch.1 ARSBR Sch.1 for on time -Total dollar amount paid in quarter -(Can use proper sampling techniques) · Details of action taken to improve performance

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Directly applicable to GRI sections, partly or wholly

Applicable to GRI sections with modifications, either partly or wholly This could be applicable to LA13, LA14 and LA15, which relate to minority groups and gender balance, depending on how data is gathered and collated. It could also contribute to answering 4.8 of the GRI

This is directly applicable to 4.17 of the GRI - key issues and concerns that have been raised through stakeholder engagement and how the organisation has responded to these. No direct relevence to GRI

No direct relevence to GRI This is directly applicable to 1.2 of the GRI - description of key risks and opportunities

By being cognisant of both climate change and the precuationary principle when conducting their risk analyses, organisations could easily use their annual reporting information to respond to GRI sections 4.11 (explanation of whether the precautionary principle is used) and EC2 (financial implications and risk due to climate change) As above

This information is applicable for reporting against GRI section 3.8 (basis Data may need substantial modification. for reporting on controllled enties) This information is applicable for reporting against GRI section 3.8 (basis Data may need substantial modification. for reporting on joint ventures, partially owned subsidiaries…)

Depending on how it is gathered, data on progress with multicultural programs could also be used to report against LA13 (composition of governance bodies) and SO1 (percentage of operations with local communtiy development programs); SO2 risks related to corruption); SO9 (operations with significant impacts on local communities) and SO10 (prevention and mitigation measures in operations with significant impacts). As above

Data used to report progress in OHS performance for annual reporting could be used to answer LA6, LA7, LA8 and LA9, depending on how it is gathered and collated. This annual reporting requirement could be used to answer EN1, EN2, EN22, EN24 and EN27, if data is gathered and collated in line with the GRI indicators.

Table 3 - Public Sector and GRI indicators descriptions and modifications Reporting requirement

Legal reference Requirement

Directly applicable to GRI sections, partly or wholly

Financial Statements

ARDA s9(1)-(2) Inclusion of Financial Statements ARSBA s7(1)(a) Controlled Entities’ Financial statements (i) -(iia) Audit Opinion on Financial Statements Response to significant issues raised by Auditor-General ARDR c4 At start and finish ARSBR c5 ARDR c5 Unaudited financial information to be distinguished by note or ARSBR c6 otherwise ARDR c6 Statement of the action taken by the Department in complying ARSBR c10 with the requirements of the Privacy and Personal Information Protection Act 1998 (PPIPA) and statistical details of any review conducted by or on behalf of the Department under Part 5 of the PPIPA. · ARSBR c12; TC In the form of a comparison with a choice of “Hour Glass 09/07 investment Facilities” from Treasury Corporation Choice of comparison based on nature and term of underlying liability Stated in terms of annual compound percentage rate of return

This information could be used directly in reatlion to EC1 of the GRI

Identification of audited financial statements Inclusion of unaudited financial statements Additional matters for inclusion in annual reports

Investment performance

Liability management performance

Performance and numbers of executive officers

Form of annual reports – generally

This information could be used directly in reatlion to EC1 of the GRI This information could be used directly in reatlion to EC1 of the GRI This is directly relevent to EC1 and PR8 of the GRI

This information could be used directly in reatlion to EC1 of the GRI

ARSBR c13; TC Only if debt is greater than $20m This information could be used directly in reatlion to EC2 of the GRI 09/07 In the form of a comparison, details of agency’s liability portfolio performance versus benchmark Benchmark is notional portfolio constructed as risk neutral per Treasurer ARDR c7,8 Number of executive positions at each level for current & prior This is directly applicable to LA1, LA14 and 4.5 ARSBR c11,14 year (or total number at equivalent to SES 1 pay or higher for SOCs or universities) Number of female executive officers for current and previous reporting years For each executive officer >= level 5 (or equivalent pay for SOCs or universities) and a chief executive officer not holding an executive position: -A statement of performance by person responsible for their review, with regard to agreed performance criteria -Details of performance pay, and summary of criteria determining this -Name, title and remuneration package -Level (except SOCs or universities) This information could be used directly in relation to sections 3.1 and 3.5 of the GRI

Energy Efficiencies Opportunity Act 2006 Energy use for the Whole Corporate Group

Information on energy assessed

Business response to opportunities assessed Cost of assessment Cost of compliance Opportunities not implemented Individual opportunities by type

Energy use for the reporting period expressed as GJ per annum. Consumption by group or business unit then totalled for the whole organisation. The amount of energy assesed in GJ broken down by type of enerygy (electricty, natural gas etc) and by business unit.

Applcable to EN3 and EN4

Applcable to EN3 and EN4

This assesses opportunities, and savings, by business unit, in Applicable to EN5, EN6 and EN7. various stages of investigation or implementation. Applicable to EN30 Applicable to EN30 Applicable to EN 6 and EN7 Applicable to EN5, EN6 and EN7.

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Applicable to GRI sections with modifications, either partly or wholly

Table 3 - Public Sector and GRI indicators descriptions and modifications Reporting requirement

Legal reference Requirement

Directly applicable to GRI sections, partly or wholly

Applicable to GRI sections with modifications, either partly or wholly

NSW Sustainability Policy reporting (using OSCAR) Energy consumption

Organisations with more than 200 staff are required to report consumption of energy and water into OSCAR

Water consumption NABERS rating

Waste Reduction and Purchasing**

Applicable to EN2 and EN3 Applicable to EN8 and EN10 This data may contribute to the calculation of energy consumption overall (EN2 and EN3), even though GRI does not require reporting of building efficiency specificallhy.

This government reporting requirement is now incorporated into the annual reporting regime.

Car fleet

No direct relevence to GRI

State of the Environment report People and the Environment Climate Change

Human Settlement

Atmosphere Land Water

Biodiversity

Specific indicators deal with population, social trends, land, No direct relevance as GRI only asks for details of grievence against cultural heritage and aboriginal significance. indigenous people and the SOE report collects data. Indicators require data on sea level rise and other climate impacts and adaptation, greenhouse gas concentration and emmissions Indicators reqiure data on water quality, water consumption, water recycling, energy supply, energy use, transport modes, waste management and noise. Indicators require data on concentrations of CO2, ozone, lead, NO2, S2O and particles Indicators require data on soils and land management and chemicals in the environment. Indicators require data on water resources, river health, wetlands, groundwater, marine waters and ecosystems and estuaries and coastal lakes Indicators require data on native vegetation, flora and fauna, reserves and conservation, invasive species, fire and fisheries.

The GHG emmissions data collated from individual departments could have some bearing on this report which is the repsonsibility of the EPA to compile. This is applicable to GRI indicators on energy consumption and water recycling (EN3, 4 and 10); and to EN30 dealing with the imapct of transport. As data not entity focused could need modification This information is applicable to GRI indicators EN16, EN17, EN19 and EN20. As data not entity focused could need modification As data not entity focused could need substantial modification This information is applicable to GRI indicators EN8, EN and, EN10. As data largely not entirely entity focused could need subsatntial modification This information is applicable to GRI indicators EN11,EN12, EN13, EN14, EN15. As data not entity focused could need substantial modification

Environmental protection licences Compliance with licence conditions***

Complaints

Key to References: ARDA ARDR ARSBA ARSBR DSA GIPAA GIPAAR IPARTA

EPL licence conditions will vary from organisation to organisation. However some of the GRI indicators mirror categories that EPL annual returns will cover. These have been mapped against the GRI as requiring moification to reflect how the real extent of EPL / GRI overlay has not been totally analysed EPL licencess are required to report on numbers of complaints. GRI indicators require data only on complaints regarding breaches of privacy.

Annual Reports (Departments) Act 1985 Annual Reports (Departments) Regulation 2010 Annual Reports (Statutory Bodies) Act 1984 Annual Reports (Statutory Bodies) Regulation 2010 Disability Services Act 1993 Government Information (Public Access) Act 2009 Government Information (Public Access) Regulation Independent Pricing and Regulatory Tribunal Act 1992

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Possible overlay with EN21, EN23, EN26, EN28 and EN29. These cover water quality discharge, spills, mitigation of environmental impacts, and fines - ie the kind of things ocovered by environmental protection licences.

Partly applicable to PR8 regarding complaints related to breaches of privacy.

PC PM PF&AA PPIPA PSEMA TC TD

Premier’s Circular Premier’s Memorandum Public Finance & Audit Act 1983 Privacy and Personal Information Protection Act 1998 Public Sector Employment and Management Act 2002 Treasury Circular Treasurer’s Direction

PO Box 3599 Sydney NSW 2000 [email protected] +61 2 9909 5777 www.globalreporting.org GRI Focal Point Australia is supported by CPA Australia and the Australian Treasury And is hosted by St James Ethics Centre