Sustainability blog is all about growing demands on stakeholders for more information, increases in regulation and the impact of long-term trends mean all organisations should focus on the sustainability of their operations, products and services.
One of the biggest impacts any organisation can have is on the health and safety of its workforce. That’s why disclosures on the management of health and safety at work have almost always featured in sustainability reporting.
And as sustainability reporting over time has become a core element of corporate disclosure suites, so too the management of health and safety at work has evolved to a more holistic, wellbeing-focussed approach. Now the world’s most widely used sustainability reporting framework is shifting the dial on corporate disclosures on work health and safety.
Health and safety disclosures – current state of play
Regardless of sector, the management of health and safety impacts are almost always featured in sustainability reporting, reflecting their importance from community, legislative, productivity, and social license to operate perspectives. The Global Reporting Initiative’s (GRI) sustainability reporting framework is the most widely cited disclosure guidance for the 90% of ASX200 companies that provide some form of meaningful sustainability disclosures in the most recent reporting period.
Despite this, disclosures have remained largely stagnant over recent years and focused predominately on lag safety indicators outlined in the GRI’s existing Occupational Health and Safety Standard (GRI-403 2016).
While Total Recordable Injury Frequency Rates continue to decline for many organisations (or plateau, with others), instances of workplace fatalities and permanently disabling injuries continue to occur, raising questions as to the value of existing disclosures –and the internal systems and processes that support them. At the same time, disclosures have largely failed to keep up with the shifting understanding of health and safety, which encapsulates a broader notion of keeping the whole worker safe and healthy whilst at work – being both physically and psychologically.
In this context it is timely that GRI has recently released a revised occupational health and safety standard (GRI-403 2018), following input from an expert multi-stakeholder working group. This is the first significant update to the GRI’s recommended disclosures in this area since the release of its G3 reporting guidance in 2006.
As we outline below, the revised standard is expected to shift the dial on corporate health and safety disclosures by facilitating more holistic and consistent insights into how health and safety issues are being managed. Although alignment with the revised standard is not required until January 2021, we anticipate a number of organisations, particularly in high risk industries with multinational footprints, will begin transitioning much sooner than this. We do however suggest caution. Whilst the standard updates are a great move forward, some of the updates do not necessarily and completely align with the requirements for managing the health and safety of workers and others in Australian workplaces.
What’s changed in the revised Standard?
The revised Standard includes the following key changes:
Change in the scope of ‘workers’ covered by Standard: The Standard covers employees and workers whose work and/or workplace is controlled by the organisation. In certain disclosures, this extends to circumstances where the organisation’s operations, products or services are directly linked to significant health and safety impacts on other workers through its business relationships
Whilst this scope of workers has expanded from previous GRI iterations, legislative instruments such as the Australian Work Health and Safety Act 2011 (Cth) go beyond the Standard and provide onus on the person conducting a business or undertaking (PCBU) to ensure workers and others are not exposed to the risk of health and safety. Importantly, the term worker was expanded to included direct employees of the PCBU, but also importantly (for example) contractors, subcontractors, and volunteers.
For example, specifically in Australia, where a PCBU has engaged a contractor to carry out work, and the contractor has engaged a sub-contractor, the PBCU has a duty of care through its supply chain to the extent that it has control and influence over the work and workplace. The law also places a duty on the PCBU to consult, co-operate, and co-ordinate its activities with other PCBUs – ‘a shared duty’. So whether or not the PCBU is carrying out the actual work or not, it should ensure that it works with its supply chain to do all that is reasonably practicable to prevent harm. Therefore, organisations will need to continue to be cognisant of inconsistencies between local legislation and the GRI’s disclosure requirements
Inclusion of positive assertions as part of the company’s management approach to health and safety: The Standard aligns to the broader principles of ISO 45001:2018 Occupational Health and Safety Management System and mandates disclosure of proactive controls in place including the status of health and safety management system design and implementation, hazard identification, assessment and management processes, incident investigation processes, scope of health and safety training provided to workers and active consultation mechanisms
Greater emphasis on occupational health: focus on the active promotion of occupational health, including access to occupational health services and how the organisation facilitates non occupational medical and health services. As part of the revision, health now stands on its own in the form of a separate management disclosure and topic-specific indicator. For organisations within high-risk sectors, disclosures on this topic have been evolving over recent years. For low risk organisations, this prompts a greater exploration, understanding and consideration of health
Refreshed methodology for reporting work-related injuries and health: As opposed to measuring the loss of productivity for work-related injuries, the emphasis is on the recovery time for the worker.
Next steps for organisations looking to align with the revised Standard
Health and Safety practitioners will be breathing a sigh of relief as these disclosures are aligned with to the broader principles of ISO 45001:2018. While alignment is not required until January 2021, early adoption is encouraged.
As organisations look to transition to the revised Standard, we recommend the following is considered:
Conduct a gap analysis of revised disclosures against current safety disclosures taking into account local legislative and regulatory requirements. This gap analysis should also look at aligning internal reporting frameworks, to enable consistent and effective reporting
Prepare for the transition by ensuring robust systems and processes are in place to capture the revised data points – especially when it comes to recording and measuring exposure hours for your extended supply chain
Develop and communicate health and safety targets in line with the GRI disclosures.
According to ACSI, 36% of ASX200 companies used iterations of the GRI framework to inform their 2017 sustainability disclosures.
The Modern Slavery Bill was introduced in Parliament on Thursday 28 June 2018 and is expected to be passed before the end of the year. If you haven’t read the Bill yet, we have compiled below our key takeaways.
Why a Modern Slavery Bill in Australia?
It is estimated that 40.3 million people were victims of modern slavery globally in 2016. Up to two-thirds of victims are believed to be in the Asia-Pacific region, where many Australian companies’ supply chains extend.
Who will need to report?
Entities with over AUD$100m global consolidated revenue, the Commonwealth, including corporates, and volunteer entities. It has been estimated that it will impacted 3,000 organisations directly.
Where do entities need to look?
The Bill is clear that entities need to look at their operations and their supply chains inside and outside of Australia.
What do entities need to report on?
Entities need to report on modern slavery risks in their operations and supply chains. These risks can include instances of human exploitation and control without the ability to leave because of coercion, mental and/or physical threat/abuse. It can take various forms, such as forced labour, debt bondage, human trafficking, and child labour.
Entities are required to submit an Annual Statement, signed by the Board, addressing:
Entity’s structure, operations and supply chains
Modern slavery risks present in the entity’s operations and supply chains
Policies & processes to address risks and their effectiveness
Due diligence and risk management processes and their effectiveness.
When do entities need to submit their first report?
The first report will be covering efforts made during entities’ 2019/2020 financial year or corresponding accounting period.
How do entities stamp out modern slavery?
Entities should start now to address the modern slavery risks in their operations and supply chain. Click here for our 5 steps approach to prepare for the Australian Modern Slavery Bill 2018.
In collaboration with our global team of experts, Deloitte Australia has created a Compliance Framework to help entities manage their modern slavery risks. For more information please contact
As we prepare for the end of financial year, and the flurry of annual reporting that it brings, many investors are eagerly anticipating a new flavour to be added to this year’s reports. This is the first full year cycle of June year-end reporting since the Taskforce for Climate-Related Financial Disclosure (TCFD) released its recommendations in late June 2017, and for many, these will be welcomed with open arms.
There have been over 330 companies sign up as TCFD supporters, as at May 2018, including many of the world’s heavyweight financial institutions. Although adoption and disclosure is voluntary, the recommended approach is to include information in respect of the TCFD within the company’s mainstream financial filings- the annual report, or the annual Operating & Financial Review equivalent.
Including disclosures around an organisation’s evaluation of climate-related risks and opportunities, and the potential financial implications, within the mainstream annual report – rather than sitting alongside other non-financial metrics in the separate sustainability report – reflects the increasing importance of climate-related issues and a maturity in risk management. This will however, require directors to ensure that they understand climate-related risks and opportunities and their impact on their organisation in more detail than ever before – elevating these risks to the audit committee, and giving climate-related risk a seat at the boardroom table.
This is important for two main reasons- firstly, the TCFD recommendations require those charged with governance to take accountability for ensuring climate-related risks are appropriately considered and managed on an ongoing basis. The recent proliferation of shareholder resolutions on climate change in Australia, and overseas underscore this point. Secondly, the evolution of auditing and financial reporting standards has led to a coinciding greater focus on Other Information, and a longer term focus in considering impairment of assets.
The confluence of these items is a critical consideration, particular in the current regulatory climate. Importantly, any new information contained in its Annual Report relating to climate change, will be considered ‘Other Information’ for the auditors, who will be required to assess this information for contradictory statements with the information contained in the Financial Statements1. Similarly, the recently released International Financial Reporting Standard 9: ‘Financial Instruments’, compels reporters to consider lifetime expected credit losses, and any significant uplift in credit risk that has occurred during the period2. Depending on your specific organisational circumstances, the physical and transition climate-related risks, may impact impairment considerations for certain categories of assets, which must be reflected in the positions taken in the Financial Statements where material.
In understanding these implications, it is evident that reporting on climate-related risks is not a one-person job, and will require an integrated effort across the company. In particular, this task should see the Sustainability team collaborating closely with Risk Management, and Finance with appropriate oversight from the board. Climate-related risks and opportunities are complex and manifest over a multiple horizons and understanding their impacts will evolve over time. The implementation of the TCFD recommendations is therefore not a one-off exercise but is expected to take some time as organisational approaches to climate-risks mature and are embedded into business-as-usual decision making.
We welcome the coming TCFD disclosures and hope that they enhance the ability of investors to understand climate risk impacts on the organisations they invest in. We also expect that organisations don’t have all the answers and many will not be disclosing on all aspects of the TCFD as they are in various stages of implementation. We encourage all organisations, no matter where they are on the TCFD implementation journey, to improve the dialogue on the impacts of climate-related risks and opportunities and demonstrate this on an ongoing basis – the coming 30 June reporting period will be the first real test on whether climate-risk is being heard at the board table.