Barriers to Strengthening the Global Reporting Initiative Framework:

Exploring the perceptions of consultants, practitioners, and researchers

Alberto Fonseca
University of Waterloo
Faculty of Environment
+1.519.888.4567 / ext. 37041
[email protected]

The Global Reporting Initiative (GRI) framework has become the global de facto standard in
sustainability reporting. The number of organizations using the framework has increased from a
few companies in 1999 to over a thousand in 2008. Accompanying GRI’s dissemination has also
been the growing number of publications highlighting its problems. To date, however, few
studies have sought to understand the barriers to strengthening the GRI model of reporting. This
paper aims to explore this challenge. First, it reviews the literature to identify some key
weaknesses of the GRI framework related to four main issues: 1) sustainability context; 2)
integrated indicators; 3) external verification; and 4) stakeholder engagement. Second, the paper
discusses the barriers to overcoming the identified weaknesses based on literature reviews and
interviews with 20 consultants, practitioners and researchers with expertise in sustainability
reporting. The paper presents and discusses a tentative diagram of the motivational, generic and
specific barriers to strengthening the framework. In conclusion, a number of practical and
research implications are highlighted.

Keywords: Sustainability reporting, Global Reporting Initiative (GRI), sustainability indicators,

frameworks, barriers, sustainability strategy, non-financial reporting.

1 Introduction

In response to society’s growing expectations of accountability, organizations have been

increasingly disclosing “sustainability reports.” The social and environmental types of non-
financial reports from the 1980s and 1990s are being rapidly replaced by sustainability ones.
This trend has been driven in part by the dissemination of the Global Reporting Initiative (GRI)
framework, a voluntary reporting tool that uses the term sustainability to describe disclosures on
the so-called three dimensions of sustainable development.

Since the publication of its first draft in 1999, GRI has been remarkably influential. It was among
the few voluntary initiatives explicitly mentioned in the Plan of Implementation of the 2002
Earth Summit (UN, 2002, p. 57). Already in 2003, a study of the World Bank found that GRI
was the second most influential global standard on corporate social responsibility practices
(Berman & Webb, 2003). Renowned global leaders like Al Gore (Russel, 2006) and Kofi Annan
(Brown, Jong & Lessidrenska, 2007) have praised the initiative, thus echoing its potential
virtues.

GRI’s growing prestige is reflected in its widespread adoption among large companies. More
than three-quarters of the world’s 250 largest companies and nearly 70 per cent of the 100 largest
companies in 22 countries are using the GRI (KPMG, 2008).The overall number of companies

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using the framework has increased from a few in 1999 to over a thousand in 2008 (GRI, 2009c).
Another unknown but likely large amount of organizations, while not explicitly adopting the
framework, follow several of its reporting rationales. GRI’s influence has also extended to other
standard-setters: “aspects of GRI thinking and process, especially the concepts of materiality and
stakeholder engagement in the development of guidelines and reports, have diffused to other
reporting frameworks and into the wider business community” (Brown, Jong & Levy, 2009). Not
surprisingly, the GRI framework is seen by many today as the global de facto standard in
sustainability reporting.

Accompanying GRI’s dissemination has been a growing number of publications highlighting its
potential negative consequences, such as promoting reports that may camouflage unsustainable
organizational behaviour (Moneva, Archel, & Correa, 2006). The imperfection of the framework
is not contested. GRI acknowledges this fact while embracing the principle of continuous
improvement. Since its launch, the framework has been through two revisions: a pace that can be
regarded as an impressive achievement, especially in comparison with other voluntary standards
(Watkins, 2008). Nevertheless, the extent to which GRI’s latest version, the GRI-G3 (GRI,
2006b), represents a positive move forward remains debatable. Several of the critiques against
the framework call for a more robust structural change in the way GRI currently frames
sustainability reporting (e.g., Aras & Crowther, 2008; Archel, Fernández & Larrinaga, 2008;
Gray & Bebbington, 2007; Henriques & Richardson, 2004; Isaksson & Steimle, 2009; McElroy,
Jorna, & Engelen, 2008; Unerman, Bebbington & O'Dwyer, 2007).

Most of these critiques have not, however, gone far beyond highlighting problems and tried to
understand the challenges involved in the incorporation of the supposedly necessary changes into
the framework. With the exception of a few studies that have hinted at the existence of path-
dependent factors and imbalances in GRI’s governance system hindering significant
improvements (Brown, Jong & Lessidrenska, 2009; Brown, Jong & Levy, 2009; Dingwerth,
2007), the barriers to strengthening the GRI framework remain largely unexplored.

The objective of this paper is to further explore this gap. More specifically, it seeks to identify
relevant barriers to the incorporation of a number of requirements raised in the literature as
necessary to strengthening the GRI framework. Such an understanding will be based on literature
reviews and semi-structured interviews with a group of consultants, reporting practitioners and
researchers with significant expertise in sustainability evaluations and reporting.

The knowledge to be presented here is relevant not only to those involved in the design of GRI,
but also to other standard-setters and policy-makers. The “desirable” framework requirements
discussed below have not been sufficiently tested elsewhere. Their implementation barriers can
be informative to those who are trying to improve other sustainability tools of mandatory or
voluntary natures. Individual organizations and industry associations searching for ways to
enhance their particular approaches to GRI reporting may also benefit from this knowledge.

The paper proceeds in four sections. Section 2 recapitulates the rise of the GRI-G3 framework
and presents its key defining characteristics. Section 3 reviews the some of the main critiques
against the framework and outlines a number of elements that could strengthen it. The
methodological approach is explained and justified in Section 4. The paper then presents and

2
discusses a diagram of the identified barriers in Section 5. Finally, Section 5 draws conclusions
and highlights practical and research implications.

2 The Birth of the GRI Model of Sustainability Reporting

Sustainable development1 is an inspiring but controversial vision. Since its popularization in the
Our Common Future report (WCED, 1987), countless institutions have embraced the concept
under a variety of assumptions and interpretations. To many scholars, most of these initiatives
have seemed more like “symbolic gestures to allay public anxieties” (Orr, 1994, p. 931) rather
than effective efforts to sustain the dynamics of the world’s socioecological systems.

In order to lessen the apparent gulf between rhetoric and reality in sustainable development,
decision-makers need indicators to help understand the complexities of societal interactions with
the environment. They also need a conceptual model or framework that, through its principles,
guidance and requirements, enables the selection and operationalization of those indicators.
Frameworks are fundamental for decision-makers. If the former are flawed, so too are the
decisions that are based on them (Bell & Morse, 2008).

Numerous sustainability indicators and frameworks initiatives have been created since the
Agenda 21 emphasized that “indicators of sustainable development need to be developed to
provide solid bases for decision-making at all levels and to contribute to a self-regulating
sustainability of integrated environment and development systems” (UN, 1992). According to
the International Institute for Sustainable Development, in November 2009 there were 842
sustainability indicators initiatives worldwide (IISD, 2009). Among them is the GRI.

GRI has its roots in the U.S.-based Coalition for Environmentally Responsible Economies
(CERES) and the Tellus Institute. These organizations were promoting environmental reporting
in the early 1990s to ensure that corporations would follow the CERES Principles for
Responsible Environmental Conduct (CERES, 1989).2 Back then, the uptake of environmental
reporting in North America was rather slow, suggesting that “it was time to look beyond the
borders of the US for markets to those that were more receptive to the idea of a generally
accepted framework […] in short, it was time for a Global Reporting Initiative” (GRI, 2007).
Moreover, a variety of co-existing, non-financial reporting frameworks, guidelines, norms,
standards and codes were becoming “messy,” thus frustrating the various parties interested in
reporting (Dingwerth, 2007, p. 103).

CERES launched the GRI in 1997 to overcome some of these problems, and, trying to boost its
global presence, partnered with UNEP in 1998 to establish a multistakeholder committee. This
committee soon advised that the GRI should “do more than the environment” and address social,
economic and governance issues (GRI, 2007). This advice was immediately incorporated into
GRI’s reporting framework and thus a sustainability-oriented reporting guide, inheriting much of

1
In this paper, the terms “sustainability” and “sustainable development” are treated as synonymous.
2
One of the 10 principles stated that “we will conduct an annual self-evaluation of our progress in implementing
these Principles. We will support the timely creation of generally accepted environmental audit procedures. We will
annually complete the CERES Report, which will be made available to the public.”

3
the rationale of the early 1990s environmental reports, was born. According to one of GRI’s co-
founders and former CEO, Allen White, the initiative emerged as a distinct one because it:

a) was governed by a multi-stakeholder steering committee;

b) [attempted] to advance true corporate sustainability reporting; and
c) [emphasized] the concept of standardization (White, 1999, p. 38).

In light of the many uncertainties involved in the practice of sustainability reporting, GRI piloted
a draft framework in 1999. The official and revised version of the framework was only published
in the year 2000 with several outreach events worldwide. By then, GRI was still “attached” to
CERES. It was not until mid-2002 that the GRI was established as an independent not-for-profit
institution. This institutional shift came also with geographical and administrative changes. GRI
was relocated to Amsterdam and Ernst Ligteringen assumed the chief executive office.

The GRI institution describes itself as “a multi-stakeholder governed institution collaborating to

provide the global standards in sustainability reporting” (GRI, 2009b). It is overseen by a board
of directors and coordinated by a secretariat. The board is comprised of 16 members from
international organizations, consultancies, accountancies, NGOs, business groups and academia.
GRI’s governance also includes a Stakeholder Council, a Technical Advisory Committee, a
Governmental Advisory group and an Organizational Stakeholder group. The institution’s
funding comes from a variety of governmental, foundational and individual sources. The
provision of learning, training and other services complement the budget. GRI’s current
framework (GRI-G3) is made up of three main elements (GRI, 2006b):

• Sustainability Reporting Guidelines: This document is the cornerstone of the framework,

as it sets quality and content principles, as well as managerial and performance
indicators. The principles for defining contents include materiality, stakeholder
inclusiveness, sustainability context and completeness. The indicators (about 130) cover
the following categories: Strategy and Analysis; Organizational Profile; Report
Parameters; Governance, Commitment and Engagement; and Indicators of Management
Approach and Performance. The latter covers, in turn, economic, environmental, social,
human rights, society and product responsibility issues.
• Indicator Protocols: These protocols provide definitions and technical and
methodological guidance on each of the performance indicators of the guidelines. Its
main objective is to ensure consistency in the application of the indicators.
• Sector Supplements: The supplements provide additional guidance and indicators for
sector-specific issues.

One of the most important changes brought up by the newest G3 version was an Application
Level (A+, A, B+, B, C+, or C) to “demonstrate a pathway for incrementally developing,
expanding, and deepening approaches to reporting over successive cycles” (GRI, 2006a). The
guidelines require organizations to self-declare their level, or hire a third-party organization or
the GRI institution to check their self-declaration.

3 A Gap Analysis of the GRI Framework

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The growing uptake of the GRI framework has been driven in part by its potential benefits.
Because of its flexibility and global reach, the framework opens opportunities to benchmark,
compare,and communicate social and environmental efforts within and across sectors. It can
serve as a tool to manage corporate reputation and pursue competitive advantage. The framework
is also relevant to report readers insofar as it provides a platform for dialogue with companies
and promotes disclosures that can underpin a variety of purposes, such as ethical investing,
political positioning and academic research. These benefits are hardly disputed. What remains
debatable, though, is whether these and other benefits outweigh the framework’s weaknesses and
unintended risks for the environment and society.

Among the most problematic aspects of GRI’s reporting model is its focus on “internal
organizational performance.” The potential dangers of this non-holistic approach have been
repeatedly highlighted by several scholars (e.g., Gray, 1996; Gray & Bebbington, 2007; Gray &
Bebbington, 2000; Gray & Milne, 2002; Henriques & Richardson, 2004; Markus J. Milne, Ball
& Gray, 2005; Markus J. Milne & Gray, 2007; Markus. J. Milne, Tredidga & Walton, 2005).
Underpinned by systems theories, the main argument of these authors can be summarized as Rob
Gray and Markus Milne (2002, p. 5) put it: that sustainability reporting needs “to have a detailed
and complex analysis of the organisation’s interactions with ecological systems, resources,
habitats, and societies, and interpret this in the light of all other organisations’ past and present
impacts on those same systems.”

Because the GRI framework encourages reporting of organizations’ “internal” performance, it

runs the risk of promoting disclosures that misses the interactive effects of organizations with the
external environment. That is, the framework runs the risk of promoting reports that misinform
readers about companies’ effective contributions to sustainable development. Rob Gray and Jan
Bebbington, seriously concerned about the lack of awareness of this contextual problem by
readers and reporters, have argued that “we must treat the current crop of ‘sustainability reports’
with the profoundest mistrust as one of the most dangerous trends working against any
possibility of a sustainable future” (Gray & Bebbington, 2007, p. 386-387).

One of the ways through which the GRI framework tries to overcome the limitations of the
“internal organizational” focus is by guiding reporters to follow the Sustainability Context
principle. This principle asks organizations to present their performance “in a manner that
attempts to communicate the magnitude of its impact and contribution in appropriate
geographical contexts” and “with reference to broader sustainable development conditions and
goals, as reflected in recognized sectoral, local, regional, and/or global publications” (GRI,
2006b, p. 12). To comply with this principle, organizations would need an analysis of their
interactions with society and the environment.

To date, however, very few GRI reporters, if any, have consistently embraced this principle,
which is the only one that does not “represent a mere interpretation of traditional financial
accounting principle” (Moneva, et al., 2006, p. 130). Mark McElroy reviewed hundreds of
reports and did not see “one that adheres to this most basic of principles. Even GRI itself, in
publishing its own sustainability reports, fails to do so” (McElroy, 2008). This situation
highlights the need for further guidance and emphasis on “context.” As McElroy and others have
put it, “while it is true that GRI advocates for sustainability context in the preparation of reports,

5
it completely fails to provide guidance for doing so, thereby ensuring that most GRI reports will
be virtually context free!” (McElroy, et al., 2008).

To effectively promote contextualized disclosures, the framework would need significant

changes. For example, in addition to “organizational” performance, companies with operations in
different geographical regions (which account for the majority of current reporters), would need
to better analyze and communicate their facility-level or site-level performances. As Bebbington
explains, “it makes more sense to talk of the SD [sustainable development] profile of a country,
region or ecosystem because SD tends to describe properties of a physical system in some
physical space.” Accordingly, it makes more sense to analyze the interactions of facilities or
industrial plants with the space surrounding them. Not surprisingly, recent attempts to
contextualize sustainability performance have restricted the analysis and communication of
performance to project or site levels (Baxter, Bebbington & Cutteridge, 2004; Bebbington, 2007;
Fonseca & Gibson, 2008).

Most reporters using the GRI framework today publish stand-alone “organizational”
sustainability reports that carry substantial aggregated data from sites located on different
geographical locations. The aggregation of this data is undertaken under a variety of rationales.
While GRI’s protocol on Organizational Boundaries (GRI, 2005) and a paragraph of the
guidelines (GRI, 2006b, p. 37) briefly highlight the dangers of aggregating some types of data
from different sites, these documents do not elaborate on how to avoid the potential dangers and
do not even mention the problem of dealing with aggregation of different geographical contexts.

Sustainability Context would also require from the GRI framework more guidance on how to
assess the state of the environment and societies impacted by companies’ operations. After all,
such information is needed to contextualize internal performance. The framework briefly
mentions this need while asking reporters to consider “recognized” publications from external
sources (GRI, 2006b, p. 12). But what can be regarded as a “recognized” publication? How to
deal with the potential lack of data, particularly at local and regional levels? Moreover, as Pablo
Archel and others have noted, understanding the state of the environment surrounding
organizations requires the consideration of the cumulative effects of organizations’ own impacts
over time, as well as of the cumulative effects of the entities operating in a particular region
(Archel, et al., 2008). While cumulative effects have been receiving some attention in impact
assessments (Duinker & Greig, 2007; King & Pushchak, 2008), they remain largely unexplored
in sustainability reporting. The GRI framework only hints at the need to consider these effects
while explaining how to interpret time within the Completeness Principle (GRI, 2006b, p. 12–
13).

Another overlooked problem of the framework is the absence of integrated indicators, which
have been regarded by many institutions and scholars as fundamental in sustainability decision-
making (Davidson, 2005; Malkina-Pykh, 2002; Morse, McNamara, Acholo & Okwoli, 2001;
OECD, 2004; Ranganathan, 1998). The GRI-G3 framework provides guidance and protocols on
how to report on dozens of social, environmental and economic indicators, but not on how to
integrate them. That is, the framework does not encourage reporters to weigh and understand
indicators’ relative values, or combine them into numerical indexes, indices and visual diagrams.
Integration is important because it allows decision-makers to keep all indicators at sight,

6
recognize their interconnectedness, identify mutually supportive benefits and better judge the
unavoidable trade-offs among sustainability dimensions (Gibson, Hassan, Holtz, Tansey &
Whitelaw, 2005, p. 113–118).

The previous version of the framework, the GRI-G2, acknowledged that addressing
sustainability in terms of pillars of economic, environmental and social indicators “can
sometimes lead to thinking about each element in isolation rather than in an integrated manner”
(GRI, 2002, p. 2). The G2 even encouraged organizations to pursue their own integrated
performance indicators in consultation with their stakeholders (GRI, 2002, p. 44–45). Such a
requirement has, nonetheless, been removed from the current G3 version. As a result, the overall
majority of GRI-based reports today are publishing performance on numerous indicators in
isolation. Aware of this limitation, some scholars are proposing ways to expand the GRI
guidelines to included integrated metrics as well (e.g., Azapagic, 2004; Lozano, 2006).

Another problematic aspect of the GRI framework is its mechanism to guide and encourage
external verification or assurance. The frequent allegations of greenwashing and cherry picking
in voluntary sustainability reporting (Henriques, 2007, p. 89) have made evident the existence of
a “credibility gap” in this practice (Dando & Swift, 2003; MacLean & Rebernak, 2007).
“Stakeholders want to be sure that the report presents a fair picture and that it is actually more
than just a PR [public relations] instrument” (KPMG, 2006, p. 6). GRI requires organizations to
disclose information on their approach to external assurance and also provides incentives to hire
these services, notably through the inclusion of the “plus” sign in its Application Level to
indicate whether reports were verified. Nevertheless, the framework provides limited guidance
on how to verify reports. It only touches on a few issues related to hiring verification services.

Recent studies have been showing several problems in the practice of external assurance, such as
extensive scope limitations, lack of comparable verification criteria and limited stakeholder
participation, among others (CorporateRegister.com, 2008a; Kamp-Roelands, Rigter & Boerma,
2008; Kolk & Perego, 2009; Manetti & Becatti, 2009; O'Dwyer & Owen, 2007; Owen, 2007).
To overcome some of these problems, other sustainability reporting frameworks, like the
Towards Sustainable Mining Framework (Mining Association of Canada, 2009) and the
Sustainable Development Framework of the International Council on Mining and Metals
(ICMM, 2008) have created specific protocols and guides for external assurance. GRI has not
attempted to do so; it simply encourages companies to look for guidance elsewhere. As a result,
companies are seeking different types and levels of assurance: a situation that undermines the
comparability and credibility of disclosures.

A similar problem happens with the framework’s stakeholder engagement requirements. Even
though GRI provides indicators and general guidance on stakeholder engagement—definitions,
examples, tests, etc. —many reporters still need to look for further guidance elsewhere. A robust
understanding of stakeholder engagement processes is fundamental in reporting, because such
engagements underpin GRI’s principles (e.g., stakeholder inclusiveness, materiality,
completeness) and have tremendous implications on the selection of and the manner through
which sustainability data is disclosed and verified. How to identify, select, engage and determine
the extent to which stakeholders should be involved in the various decision-making in reporting
is still a rather challenging issue for reporters.

7
In light of this knowledge gap, organizations have been increasingly using additional stakeholder
engagements guidelines, particularly the ones published by AccountAbility in partnership with
other institutions (AccountAbility, 2005, 2006, 2007, 2008; AccountAbility/BTGroup/LRQA,
2006; AccountAbility/Utopies, 2007). The use of the AccountAbility Series among the world’s
250 largest companies has increased from five per cent in 2005 to ten per cent in 2008 (KPMG,
2008, p. 30). Yet most GRI reporters have been using a wide variety of rationales in their
engagements. This situation also undermines reports’ comparability and credibility.

The GRI framework would need a number of additional guidance elements on “how” and “what”
to report for the purpose of addressing the problems discussed above. Figure 1 below illustrates
seven of these potential elements. These include three protocols to provide further guidance on
how to contextualize performance, verify reports and engage stakeholders. They also include
another supplement with requirements of facility-level reporting, and three standards for
disclosures of integrated indicators, cumulative effects and state of impacted socioecological
systems.

Many other elements could have been included. Because of its complexity and breadth, the GRI
framework is susceptible to various interpretations on its strengths and gaps. Nevertheless, the
seven elements presented in Figure 1 address some of the most debated issues by scholars and
practitioners concerned with GRI’s weaknesses. Understanding their implementation barriers is
an important resource for managing change towards a stronger framework and more meaningful
sustainability reports.

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 Figure 1 – GRI-G3's’potentially needed elements (adapted from GRI, 2006b, p. 3).

4 Methodology

The methods used in this study—based on qualitative, inductive, iterative and pragmatic
explanatory reasoning—follow a grounded theory approach. This approach is particularly useful
in the absence of largely tested theories or models to explain a particular social phenomenon
(Creswell, 2007, p. 66). Grounded theory’s main tenet—that explanations or theories are
“grounded” in data or in the views of participants—has enticed numerous scholars, to the point
that, in 1994, Norman Denzin stated that “the grounded theory perspective is the most widely
used qualitative interpretive framework in the social sciences today” (p. 508). There have been
many debates, however, surrounding the merits and problems of grounded theory. Today, the
“classic” method of Glaser and Strauss is one among three (Charmaz, 2006; Corbin & Strauss,
2008; Mills, Bonner & Francis, 2006). This study has followed, to a great extent, the recent
“constructivist” variant of grounded theory (Charmaz, 2005, 2006), which shares the key
procedural aspects of the original method, but interprets the “analyses in the specific historical,
social, and interactional conditions of their production, rather than constructing concepts
abstracted and separated from their origins” (Charmaz & Bryant, 2008).

The barriers involved in the enhancement of the GRI framework include factors of various
natures (e.g., conceptual, institutional, behavioural, political, procedural, cultural, etc.), which
can be valued and interpreted in different ways. In light of this complexity, this study did not aim
at reaching an overall explanation, but simply at capturing the situated perceptions of barriers
from various experts in sustainability reporting. To capture this knowledge, this paper followed

9
most of Charmaz’s (2006) suggested procedures: data collection, coding, memo-writing and
diagramming.

The qualitative data was collected through literature reviews and 20 confidential interviews
between September and November 2009. The interviews lasted from 40 to 80 minutes and were
telephone-based and audio-recorded. The main criterion used in the selection of the non-
probabilistic, purposive sample of interviewees was to capture a diversity of views. Participants
were drawn from four different groups of people who use, train, research and provide services in
connection with sustainability reporting in various countries (e.g., Canada, the United States,
Australia, South Africa, United Kingdom and Brazil). Among the interviewees were one of the
co-founders of GRI, two members of GRI’s Stakeholder Council and Board of Directors, and
employees from seven organizations that are participating in GRI’s Organizational Stakeholder
forum. Table 1 summarizes the profile of the interviewees and the reference codes used in the
discussions.

Table 1 – Interviewees’ Profiles and Codes

Group Interviewee Profile Quantity Code
GRI-certified training Experienced and certified GRI reporting trainers with in-depth
5 CC
consultancies knowledge of the framework.
International Senior consultants on corporate sustainability tools and strategies,
5 IC
consultancies including sustainability reporting.
PhD holders with extensive knowledge on corporate sustainability
Research institutions 5 RI
evaluations and reporting.
Large mining company Managers and directors of Corporate Responsibility or
5 MP
practitioners Sustainability who hire and/or coordinates GRI-based reporting.

The semi-structured interviews covered the following topics: strengths and weaknesses of the
GRI framework; barriers to promote and provide guidance on 1) contextualized sustainability
performance, 2) the state of impacted socioecological systems, 3) cumulative effects, 4) facility-
level performance, 5) integrated sustainability indicators, 5) credible, externally verified
performance, and 6) meaningful and comparable stakeholder engagements. The gaps discussed
in the previous section were briefly communicated to the interviewees after they had given their
initial opinion about the framework and the reporting process.

The data were analyzed using QSR-NVivo 8, computer-aided qualitative data analysis software.
This software3 is particularly helpful in grounded theory studies (Bringer, Johnston &
Brackenridge, 2006; Hutchison, Johnston & Breckon, 2009; Kan & Parry, 2004). The analysis
included the identification and coding of the main themes in the literature and participants’
perceived barriers. The codes were grouped according to their potential relationships in several
tree nodes, allowing for the identification of common and contrasting properties among them.
This iterative process helped to design a tentative diagram of the barriers “grounded” in the data.

3
The term “in vivo coding,” to which the software’s name refers, actually comes from grounded theory (Bazeley &
Richards, 2000, p. 24)

10
5 Results and discussions

Participants’ opinions have complemented the literature with a multitude of factors that could
hinder the implementation of the framework elements highlighted in Figure 1. These barriers
could be arranged according to a number of rationales, but the iterative analyses of the
relationships and common themes underpinning those factors have revealed a pragmatic sense in
arranging the barriers in three main groups: motivational, general and specific. The tentative
diagram of Figure 2 illustrates these groups and their respective barriers, which are further
discussed below. Some barriers are mutually exclusive while others reinforce each other within
and across groups.

Figure 2 - Tentative diagram of the barriers to strengthening the GRI-G3 framework

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5.1 Motivational Barriers

Participants from all groups have raised concerns about adding Figure 1’s additional “layers” of
guidance on the grounds of lack of motivation from both the GRI institution and reporting
organizations. Their perception is corroborated by GRI’s current agenda of priorities, which
includes a number of issues, but none directly related to those seven additional elements (GRI,
2009a). To a certain extent, there is a mismatch between GRI’s and scholars’ perceived sense of
relevance on what needs to be enhanced in the framework. A number of factors explain this
situation.

5.1.1 Voluntary nature of reporting

The predominant voluntary nature of sustainability reporting was highlighted by some

interviewees as a constraint to implementing demanding reporting requirements. For instance, a
reporting practitioner, when asked about the benefits of adding integrated measures to the
framework, saw many difficulties in doing that and claimed that “voluntarily” many companies
would not do that (MP-5).

Sustainability reporting has been primarily driven by pressures other than mandatory regulations.
Some countries, like Sweden, France and Denmark, have introduced some sort of mandatory
sustainability reporting (UNEP & KPMG, 2006), but these are the exception. In a voluntary or
non-mandatory environment, sustainability reporting needs to make business sense. Companies
engage in this practice to, for example, attract investors, respond to NGOs, facilitate “license to
operate” and pursue competitive advantage (Buhr, 2007). In doing so, they often “cherry-pick”
and disclose incomplete accounts of their negative impacts. Reporters and external assurors
complete disregard for GRI’s Sustainability Context principle provides a bold illustration of this
problem.

Mandatory reporting has a number of potential advantages, including promoting more frequent,
complete and relevant disclosures (UNEP & KPMG, 2006, p. 14–15). The GRI institution, aware
of these benefits, has been lobbying for mandatory reporting. In reaction to the recent economic
crisis, GRI’s board issued the Amsterdam Declaration on Transparency and Reporting, calling
on “all governments to extend and strengthen the global regime of sustainability reporting. In
particular, assumptions about the adequacy of voluntary reporting must be re-examined” (GRI,
2009f). One corporate sustainability researcher suggests that mandatory reporting is not “a
question of whether. It is a question of the speed and the nature, the avenues, by which it will
happen” (RI-1).

5.1.2 The GRI framework is perceived as demanding

GRI cannot halt its cycle of continual improvement while a new era of mandatory reporting does
not happen. Better ways to report need to be developed and the institution needs to be mindful of
the challenges of this practice. Setting the bar too high might inhibit the voluntary uptake of the
framework.

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While reporting should be the outcome of sustainability evaluations in principle, studies are
showing that such evaluations are usually an outcome of reporting (Buhr, 2007). Several
interviewees have noted that one of the framework’s key strengths is to help organizations
“initiate” a culture or policy of sustainability. As one of the consultants said, “the GRI provides a
standard to start a platform of dialogue towards sustainability” (CC-2). Many reporting
organizations are still setting up programs and information systems to meet the framework’s
requirements. This fact is corroborated by GRI’s recent statistics: only 20 per cent of the GRI-
based reports published in 2008 declared an A+ level (GRI, 2009c), which is supposed to
indicate a higher level of maturity in reporting.

Moreover, in spite of GRI’s growing visibility, the reality is that it is adopted by about 30 per
cent of the non-financial reporters (CorporateRegister.com, 2008b, p. 31), which represent, in
turn, a small fraction of the world’s largest companies. As Markus Palenberg and others explain,
“NFR [non-financial reporting] remains a niche practice, utilized primarily by large TNCs
[transnational corporations] based in the OECD world. However, in terms of absolute numbers,
NFR is uncommon even among TNCs” (Palenberg, Reinicke, & Witte, 2006). Almost 70 per
cent of the GRI-based reports published in 2008 came from OECD-based organizations (GRI,
2009c). And just a few of these came from small and medium-sized enterprises (SMEs).

In this context, adding more requirements on “what” and “how” to report is delicate. Even the
large OECD-based companies perceive the (incomplete) adoption of the G3 framework as
already demanding.

5.1.3 GRI’s (imbalanced) multi-stakeholder governance

Another barrier that can affect motivations to strengthen the framework is, ironically, related to
one of GRI’s most praised aspects: the broad multistakeholder governance system. This system,
seen as GRI’s “key signature” (Brown, Jong & Lessidrenska, 2009) and regarded as “an amazing
way to go about it” (CC-5), hosts an imbalanced representation of social groups, particularly in
its Organizational Stakeholder group. This democratic group is GRI’s key source of legitimacy,
as its organizations can vote for members of the Stakeholder Council and approve nominations
for the Board of Directors (GRI, 2009d).

The most robust study on the institutionalization of the GRI to date has found that “since the
initial years, participation of organized labor and NGOs has declined, partly owing to resource
constraints (for NGOs) and partly because of limited interest. Currently, large companies, banks,
accountancies, and certain think tanks that double up as consultancies for business, dominate the
Organizational Stakeholders group” (Brown, Jong & Levy, 2009, p. 573). This study concluded
that GRI’s “emerging institutional logic reflects only some of its intended constituencies, namely
multinational companies and financial institutions, and international business management
consultancies and accountancies” (Brown, Jong & Levy, 2009).

This imbalance of constituencies is currently mirrored in the Stakeholder Council (GRI, 2009e)
and may also affect the design of the reporting framework. Demanding reporting requirements
that do not necessarily meet the views of the strongest constituencies, such as business
organizations, are less likely to get approval.

13
One of the consultants whose firm participates in the Organizational Stakeholder groups revealed
another problem associated with the multistakeholder governance: the challenge of building
consensus. As he puts it, “it really takes a lot of time to make decisions, to get feedback, and
sometimes you feel like they should put down the rules or the fist on the table and give harder
guidelines, and always seek commentaries” (IC-3). Trying to reach consensus over the approval
of complicated or demanding reporting requirements among different social groups is, obviously,
a challenging process. To Mallen Baker (2006), this is actually an impossible task, as “some of
those audiences have such diametrically opposed starting points.”

5.1.4 Path-dependence in GRI’s role

On numerous occasions, interviewees argued that some of the additional elements of Figure 1,
although relevant, should not be incorporated into the GRI framework, but implemented by its
users. According to one of the interviewees, GRI should remain “focused on the core mission,
which is organizational-level disclosure, and resisting to the temptation and the pressure to do
many other things” (RI-5). Such a view reinforces Brown, Jon & Lessidrenska’s 2009 study,
which found traces of path-dependence limiting GRI’s efforts. As they put it, “GRI has thus
arrived at its maturation stage facing a plethora of challenges, many of which are grounded in the
strategies adopted by its founders” (p. 197).

Since its inception, GRI has remained faithful to providing guidance on organizational-level,
non-integrated disclosures. Practice and research have shown, however, that this focus has led to
an incomplete framework. Recent years have seen the emergence of guidelines whose purpose is
to complement GRI’s. Notable examples are the AccountAbility series and CERES’ recent
Facility-Level Reporting Project (CERES, 2005), which address the need of local-level
disclosures discussed in Section 3. This phenomenon seems to indicate a future where the GRI-
G3 will become one among various mutually reinforcing reporting guidelines.

5.2 General Barriers

Motivation is just part of the equation towards a stronger framework. There are many barriers to
enhancing reporting guidelines, regardless of who is motivated to develop them. Some of these
barriers do not depend on the nature of the changes to be implemented in the framework. They
are more general, as they stem from the weaknesses of the current GRI-G3 and of the context
within which reporting takes place.

5.2.1 Consistency among voluntary and mandatory reporting standards

The GRI framework is not being adopted within a vacuum, but within numerous mandatory and
voluntary social and environmental reporting policies that emerged in different points in time.
Mining corporations, for example, depending on the countries where they operate, may
concurrently use six different non-financial reporting frameworks covering the performance of
explorations, projects, national macro-economic contributions, and organizational responsibility.
Each of these frameworks has particular metrics and approaches.

14
A number of interviewees have raised concerns about the incompatibility among these
frameworks. Nonetheless, they have diverged as to how this problem should be addressed. For
example, one researcher stated that the more regionally focused reporting frameworks should
carry a sub-set of GRI’s indicators (RI-4), whereas a mining practitioner believes that the GRI
framework should be replicated on different levels (MP-1).

To promote more compatible reporting guidance, GRI has been increasingly partnering with
other voluntary corporate responsibility initiatives, such as IFC’s and Global Compact’s (IFC &
GRI, 2009; United Nations & GRI, 2006), but these efforts are just scratching the surface of the
variety of reporting requirements faced by companies. For instance, the synergies and conflicts
between voluntary and mandatory reporting requirements remain largely unexplored.

5.2.2 Interdependence among framework elements

While strengthening the framework, the recognition of the relationships of GRI with other
reporting initiatives must be accompanied by the recognition of interdependence among GRI’s
guiding elements. A reductionist approach ought to be avoided, as the framework’s principles,
indicators, protocols and supplements can affect each other. In this context, the challenge is not
just a matter of setting the bar too high or too low, but of how to structure and weigh the
framework’s elements. For instance, the creation of a principle such as Sustainability Context
calls for geographical-based reporting. Similarly, an increase in the number of indicators can
broaden the scope of assurors and demand more technical protocols. One of the interviewees
participating in the development of GRI’s Mining and Metals Sector Supplement (MMSS)
witnessed such a tension. She claimed that the NGOs were pressuring for more indicators
without realizing their negative implications (MP-2).

The potential implications of changes in particular framework elements can also be positive. For
instance, an adjustment of a sector supplement can help to fill the gaps of the main GRI
guidelines. Yet such potential positive effects are not always fully perceived by those involved in
the design of the framework. The development of the MMSS provides a good illustration.
Despite the relevance of facility-level reporting in the mining sector, which was corroborated by
all interviewed mining practitioners, this supplement is not being designed to encourage this
level of reporting, but simply to add more “sector issues” to be disclosed at the organizational
level (GRI, 2009g).

5.2.3 GRI’s Application Level System

GRI’s ABC Application Level System is perhaps the best example of how reductionism in the
design of the framework can lead to unintended negative consequences. The underlying purpose
of this system is to distinguish beginner and advanced reporters. It grants a “plus” sign to reports
that were externally verified, a “C” to reports with a minimum of 10 core indicators, and “A” to
reports covering all core indicators by reporting on the indicator or explaining the reason for its
omission (GRI, 2006a).

This system can, however, be misleading, because it does not require organizations to observe
other principles and reporting requirements. Accordingly, “advanced” organizations that achieve

15
a high level can overlook relevant reporting principles. This fact was corroborated by a recent
empirical study on the quality of reporting in the cement industry that found that the reports “do
not contain all relevant information for judging corporate sustainability even though they are
rated A according to the Application Levels of GRI” (Isaksson & Steimle, 2009, p. 180).

Mehrdad Nazari (2009) has also argued that this system “appears to be creating psychological
and legal barriers to sustainability reporting” (p. 128). Managers, aware that the Application
Level can be erroneously interpreted as a measure of quality, fear to publish a C-level report.
Some managers, particularly in the U.S., even decide to bypass the whole ABC system fearing
litigations that may stem from disagreements over their materiality criteria (Nazari, 2009).

Another significant side-effect of the Application Level is to discourage reporting beyond its
requirements. After all, organizations can achieve A+ by simply observing the principle of
materiality, hiring external assurance, and disclosing or justifying lack of disclosures on every
core indicator. As one of the interviewees put it, “this quest by companies to get an application
level to the GRI is probably in a way contributing to that avoidance of context. Because
companies want to report on all indicators, and get the A+ certification, they perhaps miss the
bigger picture” (IC-3).

5.3 Specific Barriers

Some barriers were found to be more specific, in the sense that they were more related to the
nature of the enhancements to be implemented in the framework. The analyses revealed literally
dozens of such barriers. Many of them hold similar properties and apply to more than one of the
elements discussed in section three.

5.3.1 Barriers to a Sustainability Context Protocol and Standard Disclosures on Cumulative

Effects and State of Impacted Systems

The application of the Sustainability Context principle depends on an understanding of the state
of impacted socioecological systems, which depends, in turn, on the evaluation of cumulative
effects. These three elements were found to share many barriers. Among interviewees’ most
cited barriers were difficulties in the acquisition of data and defining who will generate them.
Contextual information is inconsistently situated outside the boundaries of reporters. This poses
questions such as:

1) How to define the boundaries of impacted systems? (MP-3)

2) Who should generate and pay for these data? (CC-2, RI-2)
3) What indicators, unit and frequency of analysis should be used? (RI-3, MP-3, MP-4)

If each organization were to produce contextual information, there would be overlaps of efforts
and costs in geographical regions. In light of this “common” burden, many interviewees argued
that these data should not fall under individual organizations’ responsibility. The actors raised by
interviewees as better situated to address this problem were governments, industry associations,
NGOs, citizens, communities, as well as partnerships among these actors.

16
The analysis has also shown a conceptual barrier. A couple of interviewees, despite their
familiarity with the GRI framework, were clearly mixing context with materiality (MP-3, CC-4).
Such confusion is understandable, because contextual information is often used to identify
material issues. However, as one of the researches noted, context manifests in forms other than
“materiality” (RI-4).

Another interesting factor highlighted as a potential barrier to the evaluation of cumulative

effects was the dynamic nature of socioecological systems (MP-3, RI-3). The GRI framework
requires organizations to report material issues. But, because material issues are always
changing, some disclosures may not be carried over to the future, thus adversely affecting the
evaluations of cumulative effects.

In light of the many challenges and actors involved in the contextualization of performance, two
interviewees questioned GRI’s ability to standardize a technical protocol on this process (IC-3,
RI-4). Their argument was that reporting organizations should be encouraged to find their own
ways to do it. The real challenge is then to compel organizations to follow the Sustainability
Context principle and what it entails. After all, GRI’s current approach is not working (McElroy,
2008; McElroy, et al., 2008).

5.3.2 Barriers to a facility-level supplement

Barriers to promote facility-level reporting are less intimidating than those involved in the
contextualization of performance. The best evidence to this fact is that some large companies are
already doing it (M1-5 MP-4, and MP-5). The evaluation of sustainability performance at
facilities is a necessary step towards the publication of the organizational-level document. Some
companies, for the purpose being more transparent or meeting the information needs of local
stakeholders, decide to disclose the source of their data. Nonetheless, few of these local
disclosures are following the GRI framework. Facility-level reports usually come in the form of
“annexes” in the organizational GRI-based report and carrying highlights and numerical data.

A barrier that may contribute to this “incomplete” approach is the unclear cost-benefit of robust
local disclosures. As mentioned earlier, organizational-level reporting may already be perceived
as a burden for large companies, so extending it to the local level needs to make some business
sense. As one interviewee said, “Of course it would be great to have a GRI [report] at each site,
but you have to be strategic as to where you are going to focus your capacity, your efforts. So it
might not be through GRI reporting, but through community meetings, through one-on-one
meetings, or non-traditional types of reports at all” (MP-3). One of the consultants corroborated
this view while arguing that companies need to define a threshold or “size beyond which facility
level reporting becomes mandatory” (IC-5), in order to avoid a very large volume of disclosed
information.

Another hurdle in facility-level reporting is that it increases the exposure of companies and the
need for information management. A significant part of the current GRI reporters are publicly
listed companies whose financial health depends on the interpretation of their disclosures. They
need to be careful when publishing sustainability information because it can affect their
reputation and market value. One consultant shared an interesting case in which a Spanish-
headquartered company prohibited one of its facilities in South America to continue with its

17
sustainability reporting, because it was damaging the company’ image (CC-3). As opposed to
building capacity in South America, the Spanish headquarters decided to interrupt its facility’s
disclosures.

5.3.3 Barriers to integrated sustainability performance indicators

The topic of integrated performance was difficult to discuss with interviewees. It became clear
that, in the current practice of reporting, the term integration is often used to designate
disclosures of sustainability performance along with corporate financial and strategic
information. That is, the concept of integration is also being used to describe the “integrated
management and reporting approach as making reporting part of an overall management scheme
[to] improve corporate performance” (WBCSD, 2003, p. 4). Few of the interviewees were
familiar with GRI-G2’s previous call for integrated indicators.

One researcher claimed that integrated sustainability performance is what several financial
analysts are already doing to evaluate risks and opportunities within publicly listed companies
(RI-1). He cited several of these initiatives, such as the Dow Jones Sustainability Index,
Transparency Index, FTSE KLD, and Asset 4. However, another researcher questioned this
interpretation of “integration” by arguing that what these initiatives are doing is just
“aggregation”:

Aggregation you add pieces up. Do you think because you have some social reporting,
ecological and economic, and you call it the triple bottom line, and you add those things
up, you get integration? That’s not integration! That’s three different things added
together as if they were equivalent. Maybe they are in some weird way. But it doesn't tell
you how they interact. […] I am talking about interrelationships, the dynamics
interrelationships about links that are important in integration. It is much more complex.
(RI-2)

The disputed and confusing discussions on integrated sustainability performance suggest that, for
the purpose of advancing this requirement, a conceptual barrier needs to be overcome first.
Integration currently means different things to those involved in sustainability evaluations and
reporting. Only after the meaning of integration being used in this study was explained to
interviewees, did it become possible to capture their perceptions on the challenges involved in
implementing it.

Many interviewees noted that integrated indicators would probably face the same barriers
associated with the contextualization of sustainability information, because the latter is necessary
to build the former. Furthermore, they raised four main concerns about the process of weighing
and aggregating social, environmental and economic data towards integrated indicators:

- Who should decide and participate in this process? (IC-3)

- How to deal with conflicting views on the potential weights of indicators? (RI-4)
- How to aggregate indicators across different geographical facilities? (MP-1, MP-3)
- How to aggregate qualitative data in connection with social performance? (MP-2)

18
These questions make it evident that integrating sustainability performance is teemed with
subjectivity and practical challenges in the processes of weighing and aggregating data. One of
the interviewees feared that, if integration was made a requirement by GRI, organizations would
have the opportunity to manipulate data and also to promote the “weak” version of sustainability4
(RI-5). To avoid this danger, integration would need to be accompanied by the definition of clear
thresholds in connection with sensitive indicators, as well as with transparent mechanisms to deal
with the tradeoffs among them (RI-2). However, knowledge on how to address such thresholds
and tradeoffs among corporate sustainability indicators is very incipient.

Interviewees diverged on how to address these many challenges. Some suggested that GRI
should not try to standardize this process, but simply encourage reporting organizations or other
actors to do it (RI-1, IC-3). Others claimed that integration should be avoided entirely, because it
would be too time consuming and not necessarily lead to reliable results (IC-1, MP-5).

5.3.4 Barriers to protocols on external assurance and stakeholder engagement

The main barrier to the implementation of additional guidance on external assurance and
stakeholder engagement into GRI are, as discussed in section 5.1.4, motivational. GRI is not
inclined to elaborate on those elements because they are believed to fall outside the institution’s
core mission. Assuming, however, that GRI or other partnering institution is motivated to
develop further guidance on these requirements, a number of additional barriers need to be
addressed.

Both external assurance and stakeholder engagement are teeming with knowledge gaps. For
example, there have not yet been developed consensual methods to define assurance
sustainability scope/verification criteria (FEE, 2006; Owen, 2007), nor to identify, select and
engage stakeholders in the reporting process (Friedman & Miles, 2006; O’Dwyer & Owen, 2007;
Perrini & Tencati, 2006; Unerman, 2007). Some interviewees, particularly the mining
practitioners (MP-2, MP-3), commented that the current guidelines produced by other
institutions to complement the GRI framework on these topics are not sufficient (e.g.
AccountAbility, 2005, 2008; IFAC, 2004; IFC, 2007; Krick, Forstater, Monaghan & Sillanpãã,
2005; Partridge, Jackson, Wheeler & Zohar, 2005).

With respect to external assurance, the gaps are not only of knowledge, but also of human and
institutional resources. Particularly in the United States, reporting organizations are having
difficulties finding auditors and assurance firms with expertise in sustainability (CC-5). Globally,
companies also face the challenge of identifying competent individuals and firms to provide
these services. As opposed to financial assurance, which has been developing for centuries,
sustainability assurance is just beginning. The needed competencies to provide these services are
still unclear. The International Register of Certified Auditors is arguably the only institution that
currently offers a certification program for Sustainability Assurance Practitioner (IRCA, 2009).

4
Weak sustainability is a concept used in Ecological Economics to refer to a situation in which substitutions of
natural and man-made capitals are allowed, as long as the total capital of the system is sustained (Gutés, 1996;
Pearce & Atkinson, 1993). The weak approach is seen by many environmentalists as a dangerous path, because it
may overlook the limits to substitution imposed by ecosystems’ carrying capacities.

19
Yet this program is based on a particular standard (AA1000AS) that does not necessarily address
all the complexities involved in the evaluations of sustainability disclosures. Professionals of
various backgrounds in auditing and social and environmental disciplines are currently filling
this gap.

Stakeholder engagements are an essential part of reporting, because “sustainability performance

is a function of what a company impacts on vital resources relative to the need for those
resources by people who rely on them” (RI5). Stakeholders provide companies the information
they need to determine “what” should be reported. Yet, as mentioned above, there are several
questions as to how to undertake this process:

- Which stakeholder groups should be considered? (RI-5)

- How to identify representatives of stakeholder groups? (MP-1)
- How to empower stakeholders so that they feel motivated to participate? (CC-4, RI-4)
- Who should mediate and analyze the engagements? (IC-2)
- How to deal with conflicting perceptions of materiality over the same issue? (MP-1, MP-
3)

Because the answers to these questions are still unclear, reporting organizations have had
substantial room to come up with their “particular” approaches. To one of the consultants, this is
a problematic situation that can lead to manipulation of the process. As he said,

I’ve been around the block long enough to know that it is also incredibly easy, in fact far easier,
to manipulate a stakeholder process than it is to manipulate a verification process. So you can
certainly stack the deck in terms of who you get into the room, far easier than you could stack the
deck with regards to the physical measures of the emissions coming out of a particular pipe. [...]
Companies can hack that [stakeholder engagement] system too easily by creating their own
NGO groups for example. That happens, as we all know. NGOs get created and financed by
industry sectors behind two or three levels of anonymity. So it takes a long time for people to
figure out that the new group is financed by the companies, and that they are critiquing in a soft
way to draw attention from the hard stuff. Things can get very subtle and sophisticated. (IC-1)

6 Conclusion

This paper sought to identify barriers to overcoming seven guidance gaps in the GRI-G3
framework. It followed a grounded theory approach informed by literature reviews and
interviews. A tentative diagram of the various motivational, generic and specific barriers to
filling those gaps was identified and discussed, thus bringing more texture to the burgeoning
debate about the limitations of the GRI-G3. Scholars have been concerned about the potential
negative consequences of sustainability reports based on that framework.

This paper corroborates Nola Buhr’s argument that sustainability reporting is “an admirable
target to work toward,” even though this pathway might be “disputed and much longer than
many would like” (2007, p. 57). Several of the identified barriers in this study cannot be
overcome in the short term, as they depend on the generation of new knowledge and partnerships
between the various parties involved in sustainability reporting. Yet the findings also suggest that
the current regulatory and cultural reporting environment work is a disincentive to further

20
advance that knowledge and partnerships. For example, if GRI were to promote effective
contextual and integrated sustainability performance, this would inevitably lead to the
publication of less comparable geographically based reports, which go against GRI’s current
focus on the promotion of standardized organizational-based disclosures.

Unlike the ISO standards that address more specific and bounded social and environmental
management systems or issues, the GRI framework has a much more complex scope. This study
has shown that a single institution or standard-setter may not be sufficient to address this
challenge. The many guidelines that are being created to fill GRI’s gaps are starting to indicate a
future where the GRI framework will become the centrepiece of a tapestry of mutually
reinforcing reporting guidelines. A number of future studies will be needed to help establish
effective linkages among these initiatives.

This paper has highlighted specific thematic areas that need further research as well. Among
others, these include the following: mechanisms to share responsibility over the generation of
contextual data, methods to integrate sustainability performance, qualifications needed in
external sustainability assurance and processes for mediating stakeholder engagements.
Knowledge on these issues is essential to the design of more effective frameworks in the future.

There are, however, a number of practical actions that GRI can already take to strengthen its
framework. The most obvious is to confirm and recognize the discussed gaps, so that it can set
up a strategy to move towards the “ideal” framework. Several approaches, ranging from
incremental to transformational, can inform such a strategy (Dunphy, Griffiths & Suzanne,
2007). It will be, of course, up to the GRI institution to assess how equipped it is to address the
many barriers. And, for this purpose, more studies will be necessary. The identification and
discussions of the barriers in this paper reflect the sample of interviewees and literature reviews.

In spite of its limitations, this paper has provided a better sense of how strong the many barriers
to strengthening the framework can be. For example, while the standardization of contextual and
integrated sustainability performance may not be feasible in the near future, a revision of GRI’s
Application Level System can be rapidly and easily done. A simple recalibration of what GRI
regards as “advanced” or A+ level report could translate into higher quality in sustainability
reporting. Likewise, the limitations of organizational-level sustainability performance could be
more rapidly overcome if the GRI framework were more effective in encouraging organizations
to publish facility-level reports as well.

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