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standards and guidelines - consideration and engagement
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This section is currently being revised and will be available on 27th October 2003. The previous version of the Standards and Guidelines paper is shown below.
Introduction
The plethora of standards putting forward sustainable development indicators raises
challenges for those bsinesses who wish to be inclusive, but at the same time produce focused and
concise sustainability reports. Challenges are created when, in addition to those indicators
proposed by standard setters such as the Global Reporting Initiative (GRI), businesses strive to take
account of stakeholder priorities. The first draft of the
GRI guidelines (see below) proposed ninety-six
potential indicators. In order to resolve this conflict, the
bank has adopted the following broad strategy.
- For matters of Social Responsibility and Delivering
Value, the bank will primarily take account of
Partners declared priorities, as determined by
AA1000 compliant processes (see below). In
addition, the bank is actively investigating the
applicability of sector-specific initiatives, such as
SPI Finance (see below);
- For matters of Ecological Sustainability, the bank
will primarily take account of standard setters such
as GRI and the UK Government's Reporting
Guidelines (see below);
- In addition, the bank will develop 'Leadership'
indicators closely aligned to its declared business
success model, as supported by the Centre for
Tomorrow's Company1.
Standards/guidelines applicable to all business types
Social - AA1000 Launched by the Institute for Social
and Ethical AccountAbility (ISEA)2 in 1999, AA1000 is a
global social accountability standard. The bank
became the first company in the world to integrate
AA1000 with its 1998/99 Partnership Report. In 2000,
the bank was elected onto the Council of ISEA. The
bank has been involved in the development of a
framework for the first international professional
qualification for social and ethical accountants and
auditors. AA1000 underwent revision in 2001/02 and a
new AA1000 Series is scheduled for release in 2002.
It will consist of five specialised modules in
addition to a Core Standards module. The bank has
been particularly involved in the development of the
'Quality Assurance and External Verification' module,
providing both input and sponsorship. This module will
also feed directly into the assurance guidelines of the
SIGMA project and the Global Reporting Initiative. The
auditor of the bank's Partnership Report, Richard
Evans, is acting chair of ISEA, and each year provides
assurance that the bank's partnership approach meets
the expected standards set down within AA1000.
Ecology - Natural Step The Natural Step3 has, via a
programme of scientific consensus, set down the
minimum conditions for sustainable development. The
Co-operative Bank was the first UK-based company to
incorporate The Natural Step methodology in 1996,
and considers it to have been a tremendous help in
progressing its long-term aim of ecological
sustainability. Currently, The Natural Step International
is exploring whether it is also possible to agree the
minimum conditions for social sustainability, and has
established an international research programme. The
bank awaits the outcome of this programme with great
interest, but has expressed doubts as to whether it is
possible to achieve consensus on matters of social
sustainability, except at the most basic level, e.g. the
golden rule - "do unto others as you would have done
unto you." The bank has also expressed doubts as to
the degree to which it is possible to look to 'nature' for
answers to social questions. For more than 200 years,
commentators on both the left and right of the political
spectrum have 'observed' various behaviours in the
natural world and used this to rationalise a wide range
of political theories. It is the bank's opinion that the best
way to approach social sustainability at an
organisational level is via regular and extensive
stakeholder dialogue. In this way, individuals are given
a say in determining business policy on everything from
blood sports to arms exports. In each Partnership
Report, The Natural Step UK provides an assessment
of the degree to which the bank delivers value to its
Partners in an ecologically sustainable fashion.
Ecology - UK Government reporting guidelines
In 2001, the UK Department for Environment, Food &
Rural Affairs (DEFRA) produced general guidelines that
set out how to produce a good quality environmental
report4. The bank's 2002 Partnership Report is
consistent with the proposed 'reporting process', and
covers both those indicators suggested as being
"relevant to all organisations" and those indicators
considered to be additional extras. The guidance cites
the bank as one of seven examples of good practice.
Environmental targets in a whole range of areas have
been influenced by the Government's 'Making a
Corporate Commitment Campaign'5 whereby the bank
has undertaken to at least match the levels of corporate
performance being sought (and, in some instances,
has already realised such targets). DEFRA has also
published separate guidelines on how to measure and
report on the three key impacts common to all
companies: greenhouse gas emissions, waste and
water use. Again, the bank's 2002 Partnership Report
is considered to be consistent with these guidelines. In a
further development, in August 2001, the Government
consulted on the desirability of a quality assurance
standard for consumer carbon offset schemes, such as
those associated with the bank's green mortgage
products. The bank responded positively, but
emphasised that the support of well-respected NGOs
would be crucial to the reception of any scheme.
Triple bottom line - Global Reporting Initiative
(GRI) Convened by the US-based Coalition for
Environmentally Responsible Economies, GRI6 aims to
achieve the rigour and comparability for sustainability
reporting in the 21st century that financial reports
achieved in the 20th. GRI proposes a set of indicators
across the environmental, economic and social triplebottom
line. The environmental indicators are
considered by GRI and others to be much more robust
than the economic and social indicators. Therefore, as
last year, the 2002 Partnership Report has been
prepared taking account of the environmental
indicators only. With regard to the development
of sector-specific economic and social indicators in
conjunction with GRI (see 'SPI - Finance' below). For a
detailed analysis of the degree to which the bank meets
the requirements of GRI (June 2000) visit here.7
Triple bottom line - Sustainability Integrated
Guidelines for Management (SIGMA) In 1999, the
UK Government, the British Standards Institute, Forum
for the Future and ISEA launched the SIGMA Project8,
an initiative designed to explore the development of a
new generation of sustainability management tools.
The Co-operative Bank is one of 19 organisational
partners who have pledged to take the project forward,
and the bank is the sole participant from the financial
services sector. The bank has broadly welcomed
SIGMA's proposal for a triple-bottom line rules base in
which The Natural Step is a cornerstone of ecological
sustainability, and AA1000 is the basis of social
sustainability. The bank's auditor ethics etc... has been
asked, as part of the 2001 Partnership Report, to
provide assurance that the bank's partnership
approach, policies and management systems are
consistent with Project SIGMA's draft 'high level
principles' and 'rules base'. The rules for economic
sustainability still require much development.
Triple bottom line - UK National and North West
Regional Sustainability Frameworks The UK
Government and each of the regions have now
developed sustainability strategies, including triplebottom
line indicators 9. During 2000, the bank
published a report showing the degree to which its
indicators and targets supported these national and
regional strategies. During 2001, the bank was a key
player in the development and dissemination of the
North West Regional Framework, via its membership of
the North West Regional Assembly's Sustainability
Strategy Group (where it represented business). In August 2001, the bank
was amongst a group consulted as to the highest
regional priorities for ensuring continued protection
and/or improvement of the environment of the North
West. Among other feedback, the bank suggested
that 'reducing the emissions of persistent bioaccumulative
chemicals' should form the basis for a
new priority objective.
Financial - UK statutory guidelines for company
reporting - existing Current guidelines for the
statutory directors' report stipulate that the following
issues should be covered: political and charitable
contributions, employment of the disabled, employee
involvement and the period for payment of suppliers. In
addition, new guidance was recently issued on
corporate governance and internal control (the Turnbull
guidance). The bank's activity and compliance is
confirmed in its Financial Statements by KPMG
Audit Plc.
Triple bottom line - UK statutory guidelines for
company reporting - pending In 1998, the UK
Government announced that there would be a radical
review of company law. The existing framework was
established in Victorian times and is now considered to
be ill-suited to a modern, socially responsible economy.
In March 2000, to the disappointment of the bank, the
Company Law Review10 proposed only limited changes
to the duties established for company directors. On the
positive side, the Review recognised that directors
should, henceforth, be aware of wider social
responsibilities and report accordingly in a new
statutory Operating and Financial Review. However,
these 'community' reporting requirements are to be
discretionary. The bank believes that the current
recommendations would not lead to a significant
increase in the level of ethical and environmental
disclosure undertaken by businesses. If anything, the
reverse could be the case, as the statutory directors'
report currently covers such issues as political and
charitable contributions, employment of the disabled,
employee involvement and the period for payment of
suppliers. As a member of the Review's Consultative
Committee, the bank has urged consideration of the
following options:
- disclosure of 'community' issues to be made
mandatory; failing this
- as suggested, maintain the discretionary nature of
'community' disclosure, but strengthen the
penalties for willful omission and widen the scope of
audit review (drawing on appropriate external
expertise) to include the question of 'materiality'.
Triple bottom line - Other The bank's reporting of
community involvement continues to work towards the
London Benchmarking Group's guidelines11, and is
considered to meet the requirements of the PerCent
Club12. With regard to staff, Opportunity Now13, Race
for Opportunity14, the Employers' Forum on Disability15,
the Employers' Forum on Age16 and Investors in
People17 are each utilised to inform respectively on
gender, ethnicity, disability, age and employee
development. During 2001, the bank reviewed its
policies, procedures and practices against the
International Labour Orgnanisation's Tripartite
Declaration of Principles concerning Multinational
Enterprises and Social Policy18, the Organisation for
Economic Co-operation and Development's Guidelines
for Multinational Enterprises19 and the Global
Compact's Nine Principles20 and considers that it
complies with all policies, guidelines and principles.
Specific to Financial Services
Social - SPI Finance With regard to the development
of sector-specific economic and social indicators, the
bank is part of a project 'SPI Finance'21 which has
agreed a memorandum of understanding with the GRI,
the first of its kind. The project consists of 10 financial
institutions from Australia, Germany, the Netherlands,
South Africa, Switzerland and the UK, who are working
together to develop social performance indicators for
the financial industry. The key performance indicators
developed in this project will be incorporated as a
sector-specific supplement to the next issue of the GRI
guidelines, planned to be published in mid 2002. The
project incorporates a stakeholder involvement
procedure in which stakeholders are invited to provide
feedback regarding the social performance indicators
being developed. It is the bank's intention to report
against the proposed indicators within the 2002
Partnership Report.
Triple bottom line - Financial Organisations'
Review and Guidance on the Environment
(FORGE) Late in 2000, FORGE was launched with the
support of the Association of British Insurers and the
British Bankers' Association (BBA). The organising
consortium declined to respond to The Co-operative
Bank's urgings for the FORGE22 guidelines to advocate
a broad environmental policy in relation to commercial
lending (a policy that took account of matters other
than the credit-worthiness of loans, i.e. a policy that
indicates which areas will and will not receive finance).
In addition, external verification of data and
commentary is noted as an optional extra by FORGE,
and not a basic requirement for best practice. The bank
currently sees little value in pursuing the FORGE
guidance, preferring to work with GRI and the SPI
Finance Project to develop an appropriate set of triple
bottom line indicators for the financial services sector.
Triple bottom line - UK Financial Services
Initiative for the World Summit on Sustainable
Development (WSSD) 2002 In March 2001, the Prime
Minister challenged CEOs from five sectors, together
with leaders of NGOs, to develop innovative strategies
to promote sustainability in the run up to the WSSD
2002. The five sectors are financial services (FS), water,
energy, tourism and forestry. The Corporation of
London agreed to champion the financial services
sector, and Forum for the Future were appointed to
develop a set of recommendations on sustainable
finance, based on best practice at UK financial
institutions. The Co-operative Bank has acted as a key
interviewee and opinions were incorporated in a
briefing paper which informed discussions at a
practitioners workshop on 13th December 2001. Key
points made included:
- for Government to provide more certain regulatory
environment for sustainable environmental
technologies;
- for Government to encourage small-scale financial
intermediaries, such as credit unions, when seeking
to tackle social exclusion and community
investment priorities;
- distinction be made between environmental risk
assessment guidelines (which are primarily
designed to reduce risk) and environmental
screening guidelines (which aim to lessen
environmental impact, regardless of profit
opportunity);
- attention be brought to the contribution asset
finance can make to the uptake of sustainable
technologies given its relatively longer payback
period;
- Financial Services should be encouraged to
disclose across a full range of environmental issues
and produce Sustainability Reports.
A related contribution was recently posted on the
website of the Sustainable Development Commission.
Specific to Co-operatives
Triple bottom line - Co-operative Union Following a
call by leaders of the Co-operative movement, in
February 2000 The Co-operative Commission was
launched with the backing of the Prime Minister, the
Rt Hon Tony Blair MP. The remit of the 12-strong
Commission, which included the bank's Chief
Executive, Mervyn Pedelty, was to investigate and
propose ways to modernise the £9 billion UK
Co-operative movement. At the end of the 11-month
investigation, a 60-point action plan for the movement
was produced24. This included a suggestion that there
should be an increasing prevalence of, and
convergence in, social accounting and reporting
systems within the Co-operative movement. More
specifically, that:
- The Co-operative Union should establish
challenging Key Social Performance Indicators
(KSPIs) for measuring performance in relation to
Co-operative and social goals.
- The Co-operative Union should develop a standard
for social reporting, so that there is consistency
across the movement.
In the first half of 2001, the Commission's Report was
presented to co-operators at an extensive series of
meetings across the UK before being put to the
Co-operative Congress at its annual meeting at the
end of May 2001. A working Group on Social and
Co-operative performance was convened in June
2001, which included the bank, CIS and the
Co-operative Group. Priority was given to the task of
identifying KSPIs. This has proved extremely difficult, as
co-operatives come in many shapes and sizes. It is intended that a draft set
of KSPIs will be presented for adoption to the 2003 Co-operative
Congress. This time-scale does not allow for
stakeholder consultation prior to issuance.
Co-operative - Euro Coop Social Working Party
Created in 1957, Euro Coop25 represents over 3,200
local and regional consumer co-operatives, with over
21 million individual members in 13 European Union
member states and in 5 central and eastern European
countries. In 1999, the Euro Coop social working party
produced a report entitled 'Measuring the co-operative
difference'. The report explores social reporting and the
rationale for co-operative involvement in this activity.
The report proposes a set of Co-operative Indicators
based on seven principles:
- Voluntary and Open Membership,
- Democratic Member Control,
- Member Economic Participation,
- Autonomy and Independence,
- Education, Training and Information,
- Co-operation among Co-operatives,
- Concern for Community.
The bank considers that indicators based on principles
1-4 are not directly applicable to the bank as it is not
currently a membership-based organisation. Principles
5 and 7 are extensively covered within the Partnership
Report. The bank introduced a new indicator covering
the principle of 'Co-operation among co-operatives'
into its Partnership Report in 2000. |

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- www.co-operativebank.co.uk/partnership2000/audit_commentary_value.html
- www.AccountAbility.org.uk
- www.naturalstep.org.uk/
- www.defra.gov.uk/environment/envrp/index.htm
- www.macc2.org.uk/
- www.globalreporting.org/
- www.co-operativebank.co.uk/partnership2001/GRI
- www.projectsigma.com
- www.sustainable-development.gov.uk/indicators/index.htm
- www.dti.gov.uk/cld/modcolaw.htm
- www.corporate-citizenship.co.uk
- www.percent.org.uk
- www.opportunitynow.org.uk
- www.raceforopportunity.org.uk
- www.employers-forum.co.uk
- www.efa.org.uk
- www.iipuk.co.uk/
- www.ilo.org/public/english/employment/multi/tridecl/decl.htm
- www.oecd.org/daf/investment/guidelines/
- www.unglobalcompact.org/Portal/
- www.spifinance.com
- www.bba.org.uk
- www.sd-commission.gov.uk
- www.co-opcommission.org.uk
- www.eurocoop.org
To follow any of the links mentioned within the Partnership Report 2002, please visit the links page.
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