Talk:AA1000 AccountAbility Principles

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Comments on the AA1000 AccountAbility Principles -- AA Technical Committee 11:34, 17 July 2008 (UTC)

Please post your comments on the AA1000 AccountAbility Principles here

Restoring Commitment? -- David York 16:05, 15 August 2008 (UTC)

I am thinking about the principles and this document. I believe that the principles can be better introduced so as to improve understanding - particularly for new users. One aspect of that would be to deal with the AccountAbility Commitment. I propose the following outline structure in the absence of a 'wrapper' document for the AA1000 series (including AA1000SES). Comments please?

AA1000 AccountAbility Commitment and Principles

1 Introduction [Purpose and Scope]

2 The AccountAbility Commitment

3 Foundation Principle of Inclusivity

4 Materiality Principle

5 Completeness Principle

6 Responsiveness Principle

7 Relationships between the Principles

8 Using the Principles in the Context of Reporting Sustainability Performance

9 References to the AA1000 AccountAbility Principles

10 Annexes

10.1 The AA1000 Series (Relationship to other AA1000 Documents) 10.2 Definitions 10.3 Reconciliation of the Principles to the GRI G3 Reporting Principles for Defining Content 10.4 Reconciliation of the Principles to Terms Used in Financial Reporting 10.5 Evolution of the Principles 10.6 About AccountAbility 10.7 AccountAbility Technical Committee


Need to have a 'wrapper' -- David York 15:59, 15 August 2008 (UTC)

Looking at the document AA1000 AccountAbility Principles, I think that the document ought to deal with more than it does. Alternatively, when it is published the AA1000 'series' needs an overview document. As well as giving information the document could reduce duplication of material in the other documents.

I have proposed a structure for the AA1000 AccountAbility Principles document in the talk area for that.

Are the principles right? Comments from David York -- AA Technical Committee 10:19, 20 August 2008 (UTC)

Are the principles right (understandable & useful)? There is current focus on four AA1000 AccountAbility Principles: the foundation principle is inclusivity, the others are materiality, completeness and responsiveness. I think there is a general understanding of the principles, especially those now picked up in GRI G3 in the context of report preparation: materiality, stakeholder inclusiveness, sustainability context, completeness [emphasis added]. However, as I conclude at the end of this paper: I think the existing wording in the wiki is open to two lines of criticism – (a) it is not simple and understandable but conversely (b) it is not precise enough so that the principles can be assured against other than collectively. As an aside: those coming from a background of financial reporting and auditing have different uses for the words ‘materiality’ and ‘completeness’. To better make the business case, I believe AA1000 documents should explain these differences. Existing AA1000 documents refer to ‘accountability’ as follows (from AA1000SES):

The AA1000 Series defines ‘accountability’ as being made up of: • Transparency: accounting to stakeholders. • Responsiveness: responding to stakeholder concerns. • Compliance: complying with legal requirements, standards, codes, principles, policies and other voluntarily commitments.

These aspects of accountability may have very different drivers, such as legal compliance, stated policy commitments, reputation and risk management, and the company’s sense of moral and ethical duty. I believe that AA1000 (2008) should continue to refer to an organisation’s accountability so as to put the Principles into context. I do not like the above definition because (1) it uses the word ‘accounting’, so could be considered to be circular, (2) it lists the aspects of accountability but does not show their interaction (3) it does not explain sufficiently how the ‘drivers’ affect the three aspects (4) it does not allow an easy view of how the AA1000 AccountAbility principles (especially inclusiveness) relate to ‘accountability’. Having said that, the purpose of the current consultation is focussed on assurance and if the above definition can remain unaltered, it may simplify things for users. Nevertheless, looking at recent AccountAbility outputs (such as Reinventing Accountability for the 21st Century) it is clear that ‘accountability’ deserves to remain with its common language meaning and not be narrowed as it has been earlier.

I offer the following analysis of accountability in order to better support the Principles and perhaps to clarify their role or wording. During the first two wiki periods, the role of ‘inclusivity’ and of ‘embedding’ have been debated and changes made. As set out in the summary of changes document (http://www.accountabilityaa1000wiki.net/TC_Note_2.pdf)

‘The Commitment to Inclusivity has been renamed the ‘Foundation Principle of Inclusivity’ for clearer communication and understanding. There are now 4 AA1000 AccountAbility Principles and there will need to be a conclusion on each of these in the assurance statement. This ensures Inclusivity is kept as a foundation piece rather than just another principle but is intended to improve the clarity and see clearer conclusions on it.’

‘Embeddedness was not included as a 5th principle but the notion of embeddedness has been more explicitly stated across the other principles.’

AA1000 is relevant to those organisations that accept that they are accountable. In order for an organisation to be accountable there have to be (theoretically):

• Standards against which it can be judged • Information about performance against standards • Those who make the judgements (stakeholders)

There are matters of definition but using examples as a shorthand a detailed example might be:

• Policies for appropriate avoidance of child labour, established for example by discussion with trades unions underpinned by established positions, such as a related ILO Convention • Disclosure of policies and statistics, extending to the supply chain • Trades unions and other stakeholders involved in dialogue

Standards, information and judges could be seen in formal sustainability reporting as:

• The GRI G3 Guidelines • The report drawn up in accordance with those Guidelines • Stakeholders using the report

The basic premise of AA1000 is that an organisation that is accountable and accepts that it is, will take action to (1) establish the standards against which it is judged (through research or stakeholder engagement) (2) make appropriate disclosures to stakeholders (eg through published report) to enable their judgements. Acceptance of accountability only makes sense if the organisation (3) responds to the judgements to improve its compliance with the standards (which themselves will change eg over time and circumstances).

Using these three stages, it is possible to map the principles in the wiki as shown below:

Admin - please the principles right.pdf click here to view a word version of David's comments to see this analysis in table format


2. The Foundation Principle of Inclusivity Organisations adopting any part of the AA1000 Series shall commit themselves to adhering to the AA1000 AccountAbility Principle of Inclusivity, by which is meant an organisation’s commitment • to identify, understand and prioritise their stakeholders and develop appropriate engagement strategies and plans, Necessary to (1) establish standards, including appropriateness of reporting and to receive judgements • to engage stakeholders in identifying and understanding the social, environmental and economic performance and impact of its strategies and operations, Necessary to (1)establish standards, including appropriateness of reporting and to receive judgements • to consider and coherently respond (whether negatively or positively) to the needs and concerns of stakeholders in its decisions, policies and practices, and Necessary to (3) respond to the judgements • to provide an account to stakeholders of its decisions, policies, practices, actions and performance. Necessary to (2) make disclosures to stakeholders (including actions on earlier judgements) (NB elements of disclosure are present in earlier bullet points)

Note: Stakeholders are those individuals or groups of individuals who affect and/or could be affected by an organisation’s activities, products or services and associated performance. Note: The AA1000 Stakeholder Engagement Standard (AA1000SES) provides a framework for quality stakeholder engagement that will enable organisations to meet this principle.

3. The Principle of Materiality Organisations shall establish a process to determine their material sustainability issues.

This process shall be integrated with core strategy and operations. This action stems from the commitment to (1) establish the standards against which it is judged (‘material sustainability issues’)

Embedded aspect only Material sustainability issues, including social, environmental and economic issues, are determined by an organisation, supported by engagement with its stakeholders. When determining material issues an organisation shall consider the needs and concerns of those stakeholders as well as societal norms, financial considerations, peer-based norms and policy-based performance. In determining the materiality of sustainability issues the organisation and its stakeholders should evaluate why, how and at what point they are material and who they are material for. An issue is material when it is deemed relevant and important in relation to the organisation's ability to create and maintain private and public value. Material sustainability issues will inform the judgements, decisions and actions of an organisation and its stakeholders.

4. The Principle of Completeness Organisations shall be able to demonstrate that their identification and understanding of their material sustainability issues is complete

and that this understanding exists across the organisation. This refers to the quality standard for the action to (1) establish the standards against which it is judged (‘material sustainability issues’) Embedded aspect only Completeness means the comprehensive • identification of material sustainability issues and the stakeholders to whom they are material, and • understanding of material sustainability issues and their associated impacts and performance and how they are relevant and important to stakeholders.


5. The Principle of Responsiveness Organisations shall coherently respond to their material sustainability issues and appropriately communicate their responses to stakeholders.

These responses shall be embedded in core organisational strategy and operations. Necessary to (3) respond to the judgements to improve compliance with the standards Necessary to (2) make appropriate disclosures to stakeholders to enable their judgements.


Embedded aspect only Responsiveness means • responding to material sustainability issues with adequate decisions, policies and practices, while taking into consideration the sustainability context, and • communicating these responses to stakeholders without material omission or misstatement.

It is also interesting to see how the GRI G3 deals with ‘Reporting Principles for Defining Content’ The principles are stated only in relation to reporting. The report boundary is separately referred to.

GRI G3 Reporting Principles for Defining Content Related AA 1000 Principles

Materiality Definition: The information in a report should cover topics and Indicators that reflect the organisation’s significant economic, environmental, and social impacts, or that would substantively influence the assessments and decisions of stakeholders. Materiality Organisations shall establish a process to determine their material sustainability issues [the quality of the process has to be such that Completeness Organisations shall be able to demonstrate that their identification and understanding of their material sustainability issues is complete ]

appropriately communicate their responses to stakeholders.

Stakeholder Inclusiveness Definition: The reporting organisation should identify its stakeholders and explain in the report how it has responded to their reasonable expectations and interests. Inclusivity (part) to identify, understand and prioritise their stakeholders and develop appropriate engagement strategies and plans

appropriately communicate their responses to stakeholders.

Sustainability Context Definition: The report should present the organisation’s performance in the wider context of sustainability. appropriately communicate their responses to stakeholders (GRI explains that some reporting of matters external to the organisation is appropriate)

Completeness Definition: Coverage of the material topics and Indicators and definition of the report boundary should be sufficient to reflect significant economic, environmental, and social impacts and enable stakeholders to assess the reporting organisation’s performance in the reporting period. Completeness Organisations shall be able to demonstrate that their identification and understanding of their material sustainability issues is complete appropriately communicate their responses to stakeholders.

What do I draw from this analysis? Firstly, that the AccountAbility principles map completely against the three stages (standards, information and judges). Secondly, that while the principle of completeness acts as a quality standard for the process to establish material sustainability issues (materiality principle), there is no equivalent quality standard for the principle of responsiveness – which has to define as its own quality (using terms such as ‘coherently respond’ and ‘appropriately communicate’.)

The GRI Reporting Principles for Defining Content also map against the AccountAbility Principles – given that they are in the context of reporting, but similar names do not map directly to one another – eg. GRI materiality involves quality as well as (implied) process.

If you have followed this so far you may be worried that the AccountAbility Principles are being over analysed. Surely they are responsive to simple statement – in question form this is how Corporate Citizenship the assurer of SAB Miller puts it:

Materiality Does the report include the information about performance that stakeholders need?

Completeness Has SABMiller identified and understood all aspects of its performance

Responsiveness How has SABMiller responded to stakeholder concern, policies and relevant standards?

I think the existing wording in the wiki is open to two lines of criticism – it is not simple and understandable but conversely it is not precise enough so that the principles can be assured against other than collectively.

Adrian Henriques response to David York's 'Are the principles right' -- AA Technical Committee 11:12, 20 August 2008 (UTC)

I think David has made some important observations. It is just this sort of rigour which AA1000 needs. But it could lead to a fairly radical re-writing of key parts of the standard.


As I see it, David has provided an operational definition of accountability which could be the foundation of the standard. I would then like to see principles specific to assurance (to which the Quality of Information criteria for example would relate). This would certainly simplify and clarify things. To date we have been trying to shoehorn a complicated articulation of accountability (completeness, materiality, responsiveness) into guidance for doing assurance.


And it will no doubt also impact on other parts of the AA1000 family. On this interpretation, are the same principles in the assurance standard to be expected in the engagement standard? I think it would be helpful to have a common definition but separate sets of principles in each AA1000 standard, specific to the subject of the standard.


I also have some detailed responses to David’s analysis (eg I don’t believe that the standards against which stakeholders judge need to be formal) – but perhaps this sort of issue and an overall coherent response to David’s comments can be picked up at the meeting in September.

Sean Gilbert's comments in response to 'are the principles right?' -- AA Technical Committee 13:21, 29 August 2008 (UTC)

Commitment vs. Procedure Not sure if I fully understand the difference, but I think that it is another way of asking whether organizations should be assessed by an assuror against whether they have achieved an end-state (e.g., accountable and engaged) or whether they have put in place processes which might or might not have gotten the organization to the right end state.


My answer would be principles of procedure for AA1000AS, but maybe AccountAbility wants to have some other mechanism for getting at commitment or results. Ultimately, the end game of AccountAbility and any other organization in the CSR space is to stimulate behavior changes – and we shouldn’t lose sight of that. When it comes to AA1000AS though, it is a standard set up to look at how an organization has behaved – process – rather than whether it has achieved a normative standard. One of the points that I wanted to bring up on the last draft is that it wanders a bit on this point. As a whole, the document is modeled on auditing standards and in most places expresses states that it is about assuring processes. However, there are other points in the document where it implicitly or explicitly implies that it is certifying outcomes, and I don’t think that this works.


As a side note, I am not sure if I agree with David regarding stakeholders seeking commitment. I think that they first and foremost want to know that “it’s ok”. If they can’t get that, then they want to know if the organization is “on track” and “prepared”. The question of commitment runs across these to the extent that it gives some sense of confidence as to whether efforts from the organization will be maintained and improve over time. However, on its own without results or processes in place, I don’t think that commitment is worth much.


It might be possible to come up with a way to clearly assure that a company has or has not become “accountable” (I’m not sure what we would want to call it), but that is more certification in my mind than assurance. The distinction may be artificial in some ways, but it is very real in my mind. If we wanted to have a document that allowed us to assure whether the commitment had been achieved, then the document needs to set much clearer normative standards that provide clear trigger points of has/hasn’t been done. You have engaged with stakeholders at every facility vs. every country vs. every region – choosing a clear threshold/trigger. Without that, you are only looking at whether there is an engagement process in place and that it has been adequately applied, which is a process assessment. The document is already written in this tone/style and therefore I think that the principles have to reflect this.


Quality in the principles I think that quality must be reflected in the document and part of the assessment. I am less clear on whether it needs to be a principle or labeled as something else. At the moment, there doesn’t seem to be an alternative house for quality, so it drifts towards being a principle. This could be solved either by creating a new principle that refers to the quality/reliability of the information provided OR by writing the document to create a more explicit hierarchy of principles supported by characteristics (or something). It might be possible to tie to completeness, but I think that would be awkward in the end.


So yes, we need quality in the document, but finding the right home requires a bit of structural work.

Simon Zadek's views on AA1000AP -- AA Technical Committee 13:40, 29 August 2008 (UTC)

1. Absolutely right that we have a stand alone set of principles, in a distinct document...but that means of they need to mean something beyond the realm of assurance. At present, the available text does not really tell me what these principles would mean elsewhere, and I would want to see this teased out more so that we did not poorly generalise from assurance focused principles.

2. The four principles are not equivalent, but are presented as such in the wiki. Inclusivity is the over-arching principle, in effect a moral not an operational imperative...it is what we have called elsewhere the very heart of the Accountability Commitment. Firstly we seen to have lost this primacy somehow, and with it the commitment aspect. Secondly, there is only a function definition offered, and yet its primacy suggests the need for a broader ‘meaning’ before going to the functional level...inclusivity concerns in my mind the manner in which folks are held to account by those they impact. This short phrase may not be the right words (or might be), but it signals the core of what we stand for, it focuses on ‘downward accountability’ without using such clumsy language, i.e. privileges the weak rather than all stakeholders being somehow equal in our eyes.

3. Then we get to the other three principles, currently materiality, completeness and responsiveness. First on materiality. Elsewhere AccountAbility is distinguishing materiality from importance, the first being to the performance of the institution in question, and the second being what may be important to stakeholders, material or not. This crucial distinction is at the heart of much of our work now, in GLN, in RC and elsewhere, all of which have developed since the March 2003 AA1000AS definitions. I am very against going or staying backwards, focusing materiality on performance is what locks AA1000AS into the risk based governance/reporting systems, makes it relevant to financial auditing, and relevant to those committed to placing sustainability at the heart of their performance model..leaving it ambiguous does not serve a useful purpose any more. This means using what is currently ‘completeness’ as a means of focusing on what is most relevant to stakeholders, which is actually far more elegant, leaving materiality as the need to be able to relate ‘relevance to stakeholders’ to ‘material to the organisation’ in a robust manner (this is what the Materiality Report is all about). And that leaves responsiveness, which needs to be granulated but is okay.

4. Strategy and performance. Taking the route I am proposing above requires a clearer definition of organisational performance. As we know, if it is framed by shareholder interests, it will be short term in the main, whereas if the institution is AccountAbility itself, relevance/completeness and materiality will be closer together. So who ‘owns’ performance definition becomes hugely important. Clearly the starting point has to be ‘strategy’ and related goals, which have to be defined to ensure that materiality can be effectively anchored. So without a clear definition of strategy, neither materiality nor responsiveness principles can function meaningfully. These comments are of course as true for financial as non-financial reporting, most statutory auditing is useless because it is context-less – not linked to how the organisation’s value creation process works, now or going forward.

5. Accountability. So then we have to answer the question in the report, who sets strategy, or more accurately, for whom is strategy set. Setting it for short term investors is different from, etc etc...and making it clear who are the underlying accountability agents is important not just to understand strategy, but to understand the accountability context of the report. For example, a bunch of people are fired to grow margins to enable the business to be sold for more, clear accountability to existing investors who want a short term return. Reporting on the fact of the redundancies is not enough to satisfy materiality or responsiveness conditions, one has to explain why, and so for whom, who is the beneficiary of the action. This in turn is important because of the matter of who the report is for, and the duty of care of the auditor. AA1000AS needs to insist on clarifying duty of care, who they are acting for (not just who they are paid by),

Comments on the proposed AA1000 AccountAbility Principles document -- Christian 11:04, 10 September 2008 (UTC)

I think the proposed document AA1000 AccountAbility Principles is good progress and has built in many of the comments made above.

What I still would like to see is a better explanation on their application with the AA1000AS (2008) and the AA1000SES regarding the subjects of the standards and the context they are used in. It might also be helpful to state whether and how the principles can be used by reporting organisations when preparing reports (or maybe does this better fit in an extra document on reporting or is this already sufficiently expressed in the guidance.

For the purpose of an assurance standard, the principles generally are applied to make judgements about and add credibility to what an organisation is or wants to be transparent about. Asking what the corporation is or should be transparent about, in my opinion, finally comes by what David means above with “Using the Principles in the Context of Reporting Sustainability Performance”.

This touches upon the scope of the assurance standard itself, too, as sustainability performance there can be evaluated against specified criteria (Type 2), linking it to the GRI or other reporting standards, but is checked against the principles (Type 1). To enable the latter and in the case we want the principles to link to sustainability performance, I would suggest to more explicitly build in something “sustainability” in the heading of the overarching principle inclusivity, for example like:

The overarching principle of inclusivity means that an organisation accepts to be accountable to those it has a sustainability' impact on.'

When accepting accountability to those it has an impact on, an organisation gives its stakeholders the opportunity to be heard and assumes responsibility to respond to the issues and concerns of its stakeholders related to sustainable development.

Having “sustainability” in the overarching principle of inclusivity, this in my opinion relates the performance meant in the remaining three principles to sustainability and the impact on stakeholders. Therefore, I don’t think it is necessary to mention this explicitly in the process principles nor does the document need a specific explanation on that.

But because sustainability performance is and becomes more and more essential to organisational performance and to multiple stakeholders alike, this has to be reflected in each document currently under revision. In the AA1000 AccountAbility Principles I would suggest to have a sentence or two stating that (and maybe how) the standard and the guidance of the AA1000AS (2008) deal with sustainability performance.

To reflect sustainability performance in the standard itself, I would add something “sustainability” more explicitly in 6.2.1.3 The Principle Completeness of the standard, for example like:

• how the organisation ensures comprehensive understanding (including internally) of the material issues, their associated impacts on sustainability performance and how they are relevant to stakeholders.


Another thing that pops up to my mind when looking at the proposed principles is about their interrelationship and how to articulate this in the standard. The current version suggests two elements/processes with each principle (materiality = identification & prioritization; completeness = breadth & depth; responsiveness = take action & communicate). To link the principles to the standard and the guidance of the AA1000AS (2008), this structure should be incorporated there and maybe shown more explicitly. Further, as the principles interrelate with each other and so do its elements (for example an assurance provider needs to assess both, the breadth and depth of how an organisation identifies material issues; or the assurance provider needs to make a judgement whether an reporting organisation appropriately takes actions and communicates what it prioritised when determining material issues), this technically leaves you with a certain number of combinations. Because the AA1000 AccountAbility Principles are the heart of the AA1000AS, the standard and the guidance should reflect these combinations of the interrelated principles and its elements in a systematic manner. (When looking at such combinations, it might also allow to differ between scopes, provided that the standard will allow for a scope that doesn’t require evaluation of adherence to all principles).

Not sure how many of these combinations make sense to be included in the standard, but the guidance should cover and explain them all and show this in a structured way. This would help to highlight the hierarchies within the AA1000 Series and manifest its principle-based approach. When re-drafting, this might also help for checking whether everything is included in the guidance for assurance providers on evaluations of adherence to the principles.


I have also made some minor suggestions to the principles document itself which you can download here.

Removing the AA1000 principles from the AA1000AS -- Anne Gadegaard Larsen 15:55, 11 September 2008 (UTC)

In principle, I do not disagree with removing the AA1000 principles from the AA1000AS. However, it makes it very important to ensure that the right guidance is given on the following steps of the process: 1) Can the assurance provider refer to ther AA1000 principles in the assurance statement? 2) What level of integration/documentation of integration is needed before the assurance provider can make a statement on whether the principles are followed? This speaks for a separate guidance document to reporting organisations. 3) And last a detailed comment: In Chapter 1, paragraph 3 it is stated; “The standards in the AA1000 Series use these principles as their starting point. The AA1000 AccountAbility Principles provide the basis for understanding and achieving quality stakeholder engagement according to AA1000 Stakeholder Engagement Standard (AA1000SES), and sustainability assurance according to AA1000 Assurance Standard (AA1000AS).” The is a mix of stakeholder groups here; the AA1000SES is for the “reporting” organisation to understand and achieve quality stakeholder engagement and as stated by the TC in the 2nd review round the AA1000AS is for the assurance provider and not the reporting organisation; this should be made clear in this paragraph.

On the principle of Inclusivity -- Simonedecolle 16:02, 11 September 2008 (UTC)

I want to comment on the definition of the Inclusivity principle, that now states:

"organisations shall commit themselves to - identify, understand and prioritise their stakeholders and develop appropriate engagement plans...".

I would like to raise two concerns and make one related suggestions to this very important passage.

My first concern is for the use of the verb "PRIORITISE" in the principle: - What does it mean to prioritise stakeholders? - Does the standard provide normative criteria according to which stakeholders should be prioritised?

- Is the prioritisation of ONE stakeholder group's interests left to the management's arbitrary decision?

Immagine a company stating this "We understand the needs of our employees and the local community, but to fulfill our commitment to our most important stakeholder, i.e. our shareholders, we decided to close the firm in DesperateTown and fired all employees...". Would you say that this company is adhering to the inclusivity principle??? With no doubt they did prioritise their stakeholders....!

I think that we are missing one important aspect here, which is not the PRIORITISATION of stakeholder interests, but their BALANCE. The idea that INCLUSIVITY cannot be reduced to "here is the list of our stakeholders", which the vulgarization of 'prioritise' might produce, but the idea that to be accountable, it means to commit the organisation to listen, understand and try to BALANCE the stakeholder needs and aspiration.

My second concern is for the lack of reflection of the 'dynamics' (or I might say the 'evolving nature') of the stakeholders in this definition of the principle of inclusivity. As we all know, stakeholders identities are blurred and can be overlapping (e.g. I am an employee, a shareholder and a consumer of company X), stakeholder interests are intertwined - sometimes conflicting - and change over time - as John Dewey stated in 1927: “In no two ages or places there is the same Public. Conditions make the consequences of associated action and the knowledge of them different” (he defined the Public as those individuals affected by the consequences generated by associated action...so close to Freeman's definition of stakeholder). Maybe this concern can be addressed in the stakeholder engagement standard, but I think that anyway we should find a way to express this idea that understanding stakeholders aspirations and needs is not a matter that can simply be addressed by publishing "Our Stakeholder Map", as in fact on each decision the organisation generates impacts for different stakeholders, so a fixed, a-priori 'map' of stakeholders can be useful as a orientation tool, but should be taken only as a starting point and continuously reviewed/adapted with practical experimentation, with reference to the CONTEXT in which stakeholder relations take place, and with realistic stakeholder engagement approach, not looking for stakeholder categories but individuals with names, faces and families...

My suggestion, in light of the above concerns, would be to say something like:

organisations shall commit themselves to - CONTINUOUSLY identify and understand their stakeholders, and develop appropriate engagement strategies and plans in order to BALANCE stakeholder aspirations, needs and interests".

Best luck to you all and thank you for this important work!

Simone de Colle

What is public disclosure and should all statements include recommendations? -- Anne Gadegaard Larsen 16:14, 11 September 2008 (UTC)

In paragraph 5.3 “Report Boundary” it is stated that “The assurance engagement shall include an evaluation of the process used by the organisation to determine the report boundaries (time, organisational, geographical) and the results of that process, and shall evaluate those boundaries within the context of the boundaries associated with the identification, understanding and response of the organisation to its material sustainability issues.” Should it be defined what a report is ie have you considered whether the AA1000AS can also be used to assure other types of reports than annual reports (CSR, CR, SR, Sustainability, Knowledge etc.).I believe this raises the question whether all types of public disclosure - printed or web-based – annual reports or these reports – are covered by the standard. I recommend that the definition of what a report is specified further.

In paragraph 5.10.1 it is stated that “The result of the assurance process is a set of conclusions and recommendations provided by the assurance provider in a publicly issued assurance statement.” As a practitioner of integrated reporting using a ‘big four’ as the assurance provider, it will be difficult to cater for this requirement, as we due to the integration with financial requirements do not have the possibility to include the recommendations in the assurance statement as this could be interpreted as misstatements of the financial stakeholder. I therefore recommend that the requirement is adjusted to the following to cater for this specific and know situation; “The result of the assurance process is a set of conclusions and recommendations provided by the assurance provider in a publicly issued statement.” (the word assurance has been deleted). This means that the recommendations still has to be made public available in a statement by the assurance provider. However, this can be in a separate statement.

comments on principles -- Susantodd 23:01, 11 September 2008 (UTC)

Inclusivity - as expressed now, doesn't speak to the value of inclusivity that's found in diversity of viewpoints. Prioritization is problematic and seems inherently contradictory to inclusivity. While organizations rightly have to draw the line somewhere in terms of active engagement, passive inclusivity - simply being open to other points of view - could be lost through simplistic prioritization. Consultants may advise reporters that in applying this principle they should prioritize, but this shouldn't be in the standard.

Materiality - the focus on performance is too narrow and will likely be interpreted as (short term) financial performance. at a minimum please insert the word sustainability before it. i understand and appreciate the need to make the standard relevant to the financial/investment community, but i think we've lost sight of what we want organizations to be accountable for. Sustainability is a big enough issue now that mainstream interests and institutions are already starting to require that sustainability issues material to their business are reflected. what we should be concerned about are the issues that are material to the planet but operate on time scales different enough from business that they don't meet the business test of materiality. In the list of thresholds for defining materiality, consider including some biophysical, ecological or other environmental thresholds. A more radical, but useful i think, change would be to replace the word performance with contribution to sustainable development because what we really want to know in reading sustainability reports is whether these guys (in a gender neutral sense) are actually contributing to sustainable development or taking us in the other direction.

i find the distinctions between material and important to stakeholders to be cumbersome and contradictory because one of the tests of materiality is that it is important to stakeholders. Again we can recognize the need for some reasonable limits. perhaps this can be achieved by working into the definition of materiality that a material issue/action/decision significantly affects a group of stakeholders or local environment (deep or serious impact) e.g. a serious human rights concern for one village, or that it affects a significant number of stakeholders (broad impact) e.g. a persistent or pervasive nuisance to a lot of people, or the environment broadly. so we would leave out issues that are a nuisance for (or a benefit to) a small number. in practice, both the broad and deep impacts are likely to have business consequences eventually so we're not ignoring performance.

Another issue with materiality is that it has its own meaning for assurance purposes.

Completeness - awkward in that it references back to materiality. a more intuitive definition would make completeness about scope (of operations or issues) and balance i.e. have we thrown the net wide enough and not left anything out? Materiality then becomes a filter on this. Could the part about developing an understanding of the issues go into responsiveness? this would make the responsiveness principle stronger in terms of demonstrating learning.