The 'in accordance' claim under pressure
Northwind Foods, a listed dairy processor operating in four countries, is preparing its second sustainability report for calendar year 2025. The draft covers GRI 2-1 through 2-19 plus four Topic Standards. Disclosures 2-20 to 2-30 are omitted; the sustainability lead argues they are 'governance housekeeping' and not relevant to a food company. Two other items are incomplete: gender data for the Turkish subsidiary (a national data protection law prohibits collecting it) and Scope 3 transport emissions (a new logistics provider has not supplied data). The draft content index lists only the disclosures that are included. Marketing has inserted a two-page spread claiming the group is 'carbon neutral across its entire value chain', a claim resting on offsets covering 12% of measured emissions. The CEO wants the report to state that it is 'in accordance with the GRI Standards'.
1. Can the report be published as 'in accordance with the GRI Standards'? Identify every obstacle and what must change.
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No. GRI 1 conditions the claim on six things: apply the reporting principles; report all disclosures in GRI 2; determine material topics and report GRI 3 (3-1, 3-2, 3-3); report those topics using the applicable Topic or Sector Standard; publish a GRI content index; and notify GRI.
- Blanket omission of 2-20 to 2-30 breaks the second condition. GRI 2 applies to every organization; 'not relevant to a food company' is not one of the four accepted reasons for omission (not applicable, legal prohibitions, confidentiality constraints, information unavailable/incomplete). Each disclosure must be assessed separately - 2-22, 2-23/2-24, 2-25/2-26, 2-27 and 2-29 will almost certainly apply.
- Turkish gender data: legal prohibition is a valid reason for 2-7, but only for the part affected. Report total employees and the other breakdowns, name the law and the specific data affected.
- Scope 3 transport: 'information unavailable/incomplete' is acceptable only with an explanation of why and the steps being taken (contractual data clause, expected 2026 availability).
- Content index: must list every disclosure in GRI 2, GRI 3 and the Topic Standards used, with location, plus a reason and explanation for each omission.
Fix these or downgrade the claim to 'with reference to the GRI Standards'.
2. Draft the content index entries for the three problem areas.
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| Disclosure | Location | Reason for omission | Explanation |
|---|---|---|---|
| 2-7 Employees | pp. 12–13 (total, contract and employment type); regional table pp. 14 | Legal prohibition | Gender breakdown for the Turkish subsidiary (approx. 410 employees) cannot be compiled: Law No. 6698 restricts processing of employee gender data without explicit consent, which HR does not obtain. All other breakdowns reported. |
| 305-3 Other indirect GHG emissions | pp. 44–45 (business travel, upstream T&D) | Information unavailable/incomplete | The logistics provider contracted in October 2025 cannot yet supply fuel or distance data. A data clause was added in January 2026; the category will be reported in the 2026 report. |
| 2-20 Process to determine remuneration | Not reported | No valid reason available | Not applicable is not defensible for a listed issuer; the disclosure must be reported. |
Note the pattern: every row is disclosure-specific, states a reason from the closed list, and explains it. A blank row or 'not relevant' would void the claim for the whole report.
3. The 'carbon neutral across its entire value chain' spread - what is wrong with it and what should be done?
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It fails balance and accuracy. Offsets covering 12% of measured emissions cannot support a claim about the entire value chain, particularly where a material Scope 3 category is missing altogether. GRI 1 requires that reported information be sufficiently accurate and that the report not omit information that would make the overall picture misleading; sustainability context requires claims to be set against total emissions, reductions and residual amounts.
Action: rewrite to a precise, bounded statement (e.g. 'net emissions from Scope 1 and 2 of X tCO2e, of which 12% offset by verified credits; Scope 3 categories A and B not yet quantified'), disclose the offsetting approach and its boundaries, and keep marketing copy out of the reported information unless it passes the same accuracy test - anything printed in the report is reported information.