A Message to the Global Reporting Initiative from FPW

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The Global Reporting Initiative is “is a network-based organization that produces a comprehensive sustainability reporting framework that is widely used around the world. GRI is committed to the Framework’s continuous improvement and application worldwide. GRI’s core goals include the mainstreaming of disclosure on environmental, social and governance performance.” (http://www.globalreporting.org/AboutGRI/WhatIsGRI/). The GRI focuses mostly on large companies and corporations, increasing their transparency. In late November, First Peoples Worldwide, an Indigenous-led organization dedicated to working with Indigenous Peoples to achieve sustainable prosperity; Trillium Asset Management, LLC and Boston Common Asset Management, LLC, investment advisors specializing in sustainable and responsible investing; and the Oneida Trust of the Oneida Tribe of Indians of Wisconsin formulated a critique of the GRI’s G4 Revision Process. The G4 Revision Process will revise the GRI’s reporting guidelines, to be more sustainable, more mainstream, and to have a broader scope.

Here are FPW’s, Trilliums, and Oneida Trust’s comments on the G4 revision process:

“We appreciate the continuing work of the GRI Secretariat to advance and refine its guidelines to include perspectives and indicators that directly impact the livelihood of Indigenous Peoples. From our perspective, the current GRI reporting guidelines can be significantly improved by developing indicators that more explicitly address reporters’ impact on Indigenous communities (particularly with respect to cultural heritage) and how well companies are equipped to anticipate, forestall and mitigate negative impacts. Also, the GRI should more explicitly solicit companies’ positions on the question of Free Prior and Informed Consent (FPIC). Companies should clarify their policies and practices concerning FPIC, including projects where FPIC applies and doesn’t apply.
Our survey of the Guidelines shows that they address Indigenous concerns in both the Social and Human Rights sections. ILO Conventions 107 and 169 and the UN Declaration on the Rights of Indigenous Peoples are acknowledged in the Society section, and rights concerning FPIC are specifically referenced. Indicator HR9 seeks to capture the total number of incidents of violations involving the rights of Indigenous People and actions taken. These inclusions are helpful in guiding corporate disclosures.
However, we believe the document could be far more proactive by collecting a wider scope of information from reporters concerning their impacts upon Indigenous Peoples, and the reporters’ capacity to foresee and mitigate potential negative impacts. HR 9, for example, solicits data about compliance violations. Such data is useful in alerting the reader about a system failure, but should not stand as the only quantitative indicator that is collected to measure impacts — just as the Environmental section would be incomplete if only spill or emissions data were solicited without inquiring about the reporter’s capacity to prevent further pollution, and the resources devoted to that objective.
We offer the following recommendations for the G4, which we believe will greatly assist stakeholders in benchmarking companies’ policies and performance regarding Indigenous Peoples:
• List any company policies that explicitly recognize or reference the UN Declaration on the Rights of Indigenous Peoples or the ILO Conventions 107 and 169,

• State the company’s position on whether it requires free, prior and informed consent to proceed with project developments. Has the company instituted an internal management system capable of tracking the number of development projects that have been subjected to an FPIC review or other environmental and social criteria? The company should state the number of projects that have failed its review processes, and any projects that were preempted or discontinued due to that failure.

• Disclose what materials and training the company provides to its employees pertaining to the rights of Indigenous Peoples recognized by ILO Conventions 107 and 169, and the UN Declaration on the Rights of Indigenous Peoples?

• We believe the G4 should seek information regarding the extent corporations recognize and respect the cultural heritage assets of Indigenous Peoples in their decision making processes. The recent publication “Why Cultural Heritage Matters: A Resource Guide for Integrating Cultural Heritage Management in Communities Work at Rio Tinto” illustrates growing corporate interest in anticipating and managing risks associated with operating in or near Indigenous lands. We suggest that the G4 ask companies to describe materials and training a company provides to its employees pertaining to the identity, language, community and cultural heritage of Indigenous Peoples.

The G4 should require that companies describe its capacity to identify, monitor and mitigate threats to indigenous culture potentially posed by their projects. Examples might be given of sensitive areas companies should monitor, such as the preservation of sacred sites and the ability to continue traditional land use activities.

• The G4 should include indicators regarding Indigenous Peoples found in the attached April 29, 2009 letter to the GRI by the Indigenous Peoples Working Group of US SIF (formerly the Social Investment Forum). These recommendations were for the GRI’s draft version of Metals and Mining G3 Supplement but we believe they should be incorporated into the G4 itself where possible. ”

For more information, please contact Katie Cheney at kcheney@firstpeoples.org.