CORPORATE SUSTAINABILITY REPORTING

SUSTAINABLE BUSINESS
In the 1970s, businesses came under attack by environment groups, public boycotts and government legislation over the environmental damage their operations caused. Since then, many businesses have improved their environmental performance and are now trying to understand how they can operate sustainably. This section looks at the special issues facing business on the road to sustainability. Tools and techniques are presented along with examples of leadership and case studies.

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A Review of

CORPORATE SUSTAINABILITY REPORTING

Prepared by Mary MacDonald and Kim Peters for the Sustainability Reporting Program The Sustainability Reporting Program has completed a review of current approaches to sustainability reporting by business and industry. Our findings are based on reports from 20 companies that evaluate progress from the perspective of sustainability or environment, health and safety. * http://www.sustreport.org/business/report/intro.html

Introduction
The Sustainability Reporting Program has completed a review of current approaches to sustainability reporting by business and industry. Our findings are based on reports from 20 companies that evaluate progress from the perspective of sustainability or environment, health and safety. Current reporting trends have been identified and give a good indication of how "corporate sustainability" is understood by the business sector. This report: y y y discusses the conceptual issues underlying corporate sustainability reporting; explores current sustainability reporting trends; presents three templates for reporting on progress; and

recommends report elements that would demonstrate leadership in sustainability reporting.

No company is currently producing a true sustainability report, although several use a sustainability reporting framework. A sustainability report differs from an environmental report or an environmental, health and safety (EHS) report. It presents a holistic picture of company activities and provides a balanced view of benefits and trade-offs among social, economic and environmental impacts. All of the reports reviewed cover environmental performance; some also give information on economic performance as well as contributions to community and social well-being. However, none of them links all three dimensions and only a few mention a relationship between environmental and economic activities. Examples of best practice have been collected.

Our Approach
The selected corporations have headquarters in North America, Europe or Australia although most also operate in developing regions. Sectors represented include aerospace and defense, automotive and transportation, bio-industries, chemicals and plastics, consumer products, forestry and building products, health, metals and minerals processing, petrochemicals and power generation. A number conduct business in more than one sector. The reports were evaluated according to the following framework : y y y y y y y y y Audience Stated values and vision Policy on corporate reporting Decision-making principles Link between policy and operations Performance indicators Impact on profitability and competitiveness Process of information collection Approach to presentation

A NOTE ON SUSTAINABLE DEVELOPMENT

The 1992 Earth Summit in Rio de Janeiro popularized the phrase sustainable development even as the definition of the term remained vague. The many definitions and frameworks that now exist share a number of basic principles including:

y y y

Concern for the well-being of future generations; Awareness of the multi-dimensional impacts of any decision ( broadly categorized as economic, environmental, social); and, The need for balance among the different dimensions across sectors (e.g. mining, manufacturing, transportation), themes ( climate change, community cohesion, natural resource management) and scale (local, regional, national, international).

The elusive goal of sustainable development, or sustainability as it is also called, is to make decisions and carry out programs and projects in a manner that maximizes benefits to the natural environment and humans and their cultures and communities, while maintaining or enhancing financial viability.

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Conceptual Issues
Why Do a Report?

Companies produce a corporate sustainability report (CSR) for many reasons. There is seldom a single reason and the rationale for producing the report can change over time. Motivating factors include: y y y y y y y Providing information about challenges and achievements to shareholders, employees, the public and other stakeholders; An internal commitment to environmental and social responsibility; As a marketing tool, associating the company with sound environmental management and sustainable activities; Tracking progress on integration of sustainability principles into company planning and programs; Taking first steps towards doing things in a more sustainable way; A successful pilot project persuaded decision-makers to take the initiative company-wide; and A commitment to remaining competitive while becoming a world leader in sustainability.

Many of the companies who have completed a CSR began with environmental reports that documented how the organization was meeting environmental regulations. In some cases, the approaches and tools used to meet regulations, such as more efficient process design, also made good business sense. Individuals like Paul Hawken and organizations such as the World Business Council for Sustainable Development have worked to publicize the economic, social and environmental benefits associated with operating more sustainably. Reporting on achievements in this area can enhance a company's public image but it also presents an opportunity for locating costly waste and inefficiency. Core Values A statement of company values can provide direction and rationale for the report. Wording is important. Clichd catch-all phrases ("Building a Better Future") are unconvincing and difficult to measure. Saying that sustainability is important but failing to reflect this in stated company values raises doubts about the sincerity of the commitment. Setting Priorities Good sustainability reporting builds on core values and sets out decision-making principles that are consistent with these values. Sustainability reporting frameworks can provide a broader context for linking priorities rather than viewing them as competing objectives. Examples of sustainability decision-making principles used in the reports include: y y y y y maximizing shareholder value while improving environmental performance and contributions to the local community; EHS principles of best practice Life cycle analysis Total cost assessment CERES principles

The Business Challenge Businesses must make money. No matter what other goals and ideals directors and employees bring to the organization, staying in business and prospering is a fundamental value of any for-profit enterprise.

Supporters of sustainability insist it makes good business sense. Approaches such as eco-efficiency are based on a common sense proposition that reducing waste and inefficiency in production processes can save money and protect the environment at the same time. Life cycle analysis (LCA) offers a theoretical framework for understanding material flows and potential impacts involved with providing services or products in a closed loop. Sometimes referred to as "cradle to cradle" or "cradle to grave", LCA looks at an entire enterprise in term of input, throughput and output. This helps to identify inefficiencies that drain profit and produce waste including pollutants. Norsk Hydro has used this framework for significant portions of its corporate report. Triple bottom line evaluating company performance according to a summary of costs and benefits to the corporation's finances, the communities where it operates and impacts on natural resources is another method for presenting and/or assessing corporate sustainability. Many of these approaches e.g. eco-efficiency, full cost accounting, LCA, systems-based pollution prevention, industrial ecology are new to the business world. Even academic proponents of sustainability acknowledge the great number of uncertainties and contradictions associated with attempts to apply the concept to day-to-day operations. Therefore, companies setting out to produce a corporate sustainability report must show how business objectives such as profit and competitiveness are consistent with sound environmental management and/or sustainability principles. The failure to make this connection is a weakness in many reporting initiatives. It makes a report appear superficial and a low priority. For credibility, the environmental/sustainability approach must be presented in a context that demonstrates its real value to the company. The Royal Dutch/Shell Group of Companies is on the right track. The chairman kicks off the report by saying: "My colleagues and I are totally committed to a business strategy that generates profits while contributing to the well-being of the planet and its people. We see no alternative". The report that follows uses real-life examples to show how Shell's implementation of a sustainable development management framework has created business value by reducing costs, creating options, gaining customers and reducing risk. Connecting Policy to Operations Making broad policy statements is easy. The real test of commitment is implementation. This is particularly difficult in the field of sustainability where decisions can be guided by general principles but much practical application is still a matter of trial and error. If the stated values and principles have any meaning to a company outside the need for reporting to the public, there will be obvious connections among the corporate management team, senior operations staff and employees generally. Companies that can demonstrate these connections e.g. specific examples where policy has affected operations, the nature and extent of staff education and training, a responsibility flow-chart generally have very convincing reports. Reports that dwell on policy statements with no concrete results give the impression that the CEO and other senior corporate managers may understand the challenges but that this knowledge has not been translated into tracking and evaluating progress or any real change inside the company.

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Trends in Sustainability Reporting

General Reporting Approaches Leaders in corporate sustainability reporting (e.g. Royal Dutch Shell, Bristol-Myers, Norsk Hydro) are active in international reporting initiatives spearheaded by organizations such as the World Business Council for Sustainable Development (WBCSD) and the Coalition for Environmentally Responsible Economies (CERES). The Global Reporting Initiative (GRI) has worked with representatives of many sectors to develop guidelines for reporting on sustainability. General Motors and Norsk Hydro both tested the draft guidelines for their 1999 environmental reports. The 20 reports reviewed here, however, employ a variety of reporting approaches. Most are a hybrid of: y Learning curve - many reports stress that they are taking first steps in integrating environmental, social and economic factors into company policies and operations or that they are just learning how to do environmental/sustainability reporting. Some reports truly are early efforts but even companies with a lot of experience sometimes claim to be beginners. Anecdotal (little data) - these reports are full of short stories on different company projects or programs but include few numbers. EMS/ISO 14001 - these reports focus on illustrating effective management and production systems and often include indicators and targets for improved performance. CERES/GRI guidelines, triple bottom line - the current standard for presenting environmental, social and economic information. Generally, these reports provide side-by-side information (e.g. separate sections on environment and social responsibility) rather than integrated overviews. Integrated reports - progress on environment, health, safety and/or sustainability is presented as an important part of the company's annual report. This is the newest trend in corporate sustainability reporting (Procter and Gamble). Innovative reports - the challenge is to strike a balance between the "me too" reporting of set frameworks and a report that is customized to the needs and objectives of a particular company. (Shell).

y y y

Portrayal of Performance y Context - the best reports provide information on how the sustainability (or EHS) report relates to other company reporting initiatives (e.g. financial statements). They also give trend line data presenting current information in the context of past data. Data collection - most reports do not indicate how information was collected. Others provide an outline of how management, different divisions and individual units all contributed to the report. In one case, assembling information to evaluate performance resulted in a restructuring of the company. A clear, concise description of how data is collected underlines a company's commitment to detailed and responsible reporting. Rio Tinto presents this information in a flow chart that illustrates how both corporate policy and operation specialists in the company drive the reporting process. Indicator clusters - for environmental reporting the most common indicators are grouped around emissions and energy efficiency. For sustainability reports, social, economic and environmental information is frequently reported in separate sections. The absence of agreed upon social indicators is a common thread throughout the reports. Level of detail - several reports provide little meaningful data. A report is data-poor when the only quantitative data is percentages in some pie charts. Data aggregated to the company level

illustrates a sense of responsibility for all operations. The Rio Tinto report points out the need to identify which indicators are more meaningful when presented at the company wide level (e.g. total emissions of CO2) and which ones have the greatest impact at the local level (e.g. discharge to surface water). A strategic focus on tracking progress in the areas of most concern to the company (e.g. Procter and Gamble emphasizes water quality and health and hygiene) is one method of determining which data deserve priority. Targets - stated targets show commitment to monitoring performance. Company-wide targets related to the environment/sustainability report help employees see the practical implications of broad policy. Targets can be based on meeting minimum certification requirements (e.g. ISO 14,031) or international agreements (e.g. Kyoto Protocol) or on setting goals for constant improvement year-by-year within an individual company (e.g. reductions in NOx emissions, less use of energy per unit of product).

The Reporting Team Reports that appear to genuinely reflect what is going on inside a company come from a reporting team headed by a senior executive (Senior VP, CEO, Company Director) and include representatives from both the corporate policy and operational divisions. Geographical representation is a plus but representation from different divisions greatly increases the probability of the report having value both inside and outside the organization. It is also in keeping with sustainability principles. Building Credibility A report looks as if it's been written by the communications department if it contains little more than broad policy statements and, in some cases, references to global agreements and events. It will read as an attempted "greenwash" even if the company has real information to share about its sustainability accomplishments. Factors that influence credibility include: y y Stakeholder participation - showing how input from different stakeholders has improved performance demonstrates a sincere commitment to community participation. Honesty in reporting - reports that include results of environmental (and economic) audits and other forms of outside verification can build confidence in a company with a less than stellar public image. However, the controversial figures must be verified. Getting external verification for a non-controversial figure like quantity of energy consumed and then failing to verify contentious information like the level of dioxin emissions can heighten suspicion of the data and the whole report. Admitting limitations - for some activities, there may be a tendency to tell only part of the story. This can backfire since raising the issue will provoke questions about what has not been done. Verification is one example of this. Another is life cycle analysis. Some reports explain how the company operates on the principle of life cycle analysis. On close inspection, it emerges that while the production process is viewed from a life-cycle perspective, the impacts of the actual end use of the product (cradle to grave material flows) are not figured in. Credibility is built by demonstrating a clear understanding of an approach, including where the company falls short and why. Companies should be careful to strike a balance between positive and negative results. Consistency - stressing the importance of sustainability to the company but neglecting to show how it relates to core values and business activities detracts from credibility. http://www.sustreport.org/business/report/trends.html

Templates for Best Practice Reporting

In spite of efforts from bodies such as the Organization for Economic Cooperation and Development and GRI to push for standard reporting formats, no two sustainability and EHS reports are the same. The reasons can be obvious. Reporting on different processes such as mining and paper production or addressing different audiences can have a major impact on report format and data presentation. Differences can also result from more subtle aspects such as inexperience or poor writing and presentation skills. The following reporting templates group suggested report elements around three basic approaches, each aiming for a different main objective:

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Creating a Positive Impression

Objective: building trust, information and education Audience: general public, shareholders, socially responsible investors Availability: on the web and in printed form Writing and Presentation: More graphics than text on each page. Points should be made in a very concise manner. No short forms (e.g. sulphur dioxide not SO2). Limited presentation of concepts and general policies. 1. Table of contents illustrating how different sections fit together (important for clarity of message). 2. Description of company - what it does, location, number of employees, where stock is traded (educates public about the company). 3. Statements from CEO and senior executive in charge of sustainability reporting (identifies sustainability as a corporate priority). 4. Statement of how company values/vision including profit and growth are linked to sustainability (illustrates commitment and understanding of the sustainability concept). 5. Overview (could be a two-page diagram) of how company activities fit together under a sustainability umbrella (demonstrates awareness of internal links and cause/effect relationships across areas of activity). 6. Explanation of how sustainability reporting is accomplished (reporting team should be accountable to the Board of Directors; flow-chart or description of how sustainability policy and implementation can be tracked throughout the company; acknowledge deficiencies and indicate how things will improve in the future - e.g. training). 7. Summary of company-specific sustainability challenges and achievements (requires a strategic evaluation of the key factors that make a difference in progress on sustainability; detailed analysis shows commitment). 8. Statement of targets for key sustainability indicators (derived from international standards (e.g. ISO 14,000 series), national regulations and company's voluntary measures). 9. Aggregated data (in trend line form, if possible) to support statements in section 7. 10. Site-specific data for problematic or exemplary conditions (illustrates success and willingness to face problems head-on therefore increasing likelihood of finding solutions). 11. Results of external audit (internal audits do little to build credibility with the public).

12. Going beyond what is expected e.g. update on employee or community awards program for innovations that help with company progress towards sustainability (optional but effective in building and demonstrating commitment). 13. Feedback form (make most interesting positive and negative comments available on web site and have staff reply where needed). 14. Identify who to contact for more information. 15. Glossary of technical terms.

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Making the Business Case for Sustainability

Objective: Illustrating that sustainability is good for business. Audience: Shareholders, employees, potential investors. Availability: Web site, limited number of executive summaries in printed form. Writing and Presentation: Roughly equal amount of text and graphics per page. Do not use short forms (e.g.: greenhouse gases not GHG). Explanation of some broader concepts to link business and sustainability perspectives (e.g full cost accounting) will be necessary but should be illustrated using reallife company examples. Err on the side of too little text. 1. Table of contents showing how different sections fit together (important for clarity of message). 2. Description of company what it does, location, number of employees, where stocks are traded (illustrates the extent of company holdings and activities). 3. CEO and Chairman of the Board statement about why the company is excited about sustainability and its effect on competitiveness (identifies sustainability as a corporate priority). 4. Statement of how company values or vision, including profit and growth, are linked to sustainability (illustrates commitment and understanding of the sustainability concept). 5. Explanation of changes resulting from tracking company progress on sustainability new expenditures, cost savings, employee training, operational adjustments, reduced/increased emission levels (acknowledge deficits in this area and indicate how things will improve in the future - e.g. payback period on capital expenditures). 6. Description of how sustainability reporting is accomplished within the company and how that relates to and affects financial outcomes and reporting (reporting team should be accountable to the Board of Directors; flow-chart or description of how financial and environmental data collection is linked to management and operational policies and programs). 7. Financial statement (summary of annual report to shareholders). Summary of company-specific sustainability challenges and achievements (requires a strategic evaluation of factors that make a difference; allows company to focus on the actions most likely to yield positive results). 8. Integrated indicators that link economic performance with environmental improvements and, where possible, employee and community well-being. (Data should be aggregated or local as appropriate). 9. Data on environmental performance. 10. Results of external financial and environmental audit. 11. Company goals and targets for coming year.

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Global Reporting Initiative Sustainability Guidelines on Economic, Environmental and Social Performance (June 2000)
Objective: Standardize information collection on company sustainability Audience: general public, shareholders Availability: current tendency to web-only reports allows year-round updates and reduces use of paper. 1. CEO statement GRI does not require specific elements to be covered but recommends a number of issues be addressed such as acknowledgment of successes and failures, performance against benchmarks and major industry challenges. 2. Profile of reporting organization includes company characteristics such as number of employees, description of business activities, where stock is traded. 3. Executive Summary and Key Indicators - the specified generally applicable environmental performance indicators (e.g. total energy use, total materials use other than fuels or water) - selected organisation-specific environmental performance indicators (e.g. company initiatives to move towards renewable energy sources and energy efficiency, use of recycled materials with pre- versus post- consumer use distinctions) - selected economic performance indicators (e.g. net profits/earnings/income, investments in research and development, debt/equity ratio) - selected social performance indicators (e.g. employee retention rates, ratio of jobs offered to jobs accepted, investment per work in illness and injury prevention) -selected integrated performance indicators (e.g. total materials used during a product's life cycle expressed relative to globally sustainable levels measured in terms of resource availability and/or biophysical or assimilative capacity). 4. Vision and Strategy outlines the company's vision for the future and how it will manage the challenges associated with economic, environmental and social performance. 5. Policies, Organization and Management includes the company's mission statement, explanations of how the precautionary principles is represented in company policies, management systems in place and current stakeholder relationships. 6. Performance Indicators this section should present more indicators (quantitative and qualitative) in the categories described in Step 3. Strengths and Weaknesses of GRI Guidelines The guidelines are the result of several years of cross-sectoral cooperation to identify a methodology for reporting on sustainability. They rely on the types of data that are often already collected for other purposes. The aim is to gain a better understanding of what sustainability means by developing a standard approach that will allow for comparison. The guidelines are biased towards environmental information, reflecting both the emphasis placed on a healthy ecosystem by those who developed them and the difficulty of tracking social and economic information in a corporate context. Policy is the cornerstone of the GRI approach. For the most part, it overlooks the connection between management policy and operational implementation that is vital to presenting a complete picture of progress on company sustainability. The GRI recognizes the importance of including more integrated indicators, such as ones that link across company divisions or identify connections between local operations and global conditions. This area is not yet well-developed.

The views and priorities of those operating in developed countries have shaped the development of the GRI guidelines. The project may benefit from inclusion of input from developing regions for a truly global perspective.

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Examples of Best Practice

A Comprehensive Reporting Structure Rio Tinto includes an excellent graphic to illustrate responsibilities and information flow relating to the preparation of the company's Social and Environment Report.

This makes it apparent that Rio Tinto understands the importance of bringing corporate policy makers together with operational managers to produce a report that has meaning inside and outside of organization. Strategic Focus on Data Procter and Gamble builds credibility and uses resources most effectively by providing detailed data on areas of greatest concern to the company. In the 1999 Sustainability Report emphasis was placed on water quality and use and on health and hygiene. Other more general indicators of progress were also reported upon but the detailed assessment in two areas gives the impression that the company is looking for triggers of improvement in areas where they are needed the most. Connecting Life Cycle Assessment to Financial Performance Norsk Hydro has applied life cycle assessment to the workings of the entire company. The aggregated data allows for a striking overview of company consumption of natural resources and pollutant emissions in light of annual profits. LCA has also been completed for each major company division.

Electrolux has also reported on the life cycle analysis of a number of their products. A strong impetus for the appliance industry to offer products with reduced environmental impact is the fact that the main environmental impact is usually greater in product use than during production, and furthermore is closely connected to the individual household economy. A life cycle assessment of a washing machine for example shows that about 80 percent of the total environmental impact during the life of the machine consists of water, energy and detergent consumption. A similar analysis of the total cost of the entire life cycle of the machine shows that the cost of water, energy and detergent consumption exceeds the initial purchase price. For the customer, this means that choosing an appliance with a high environmental performance also means long-term savings. For the appliance industry it means making consumers aware of this connection. Replacing old, inefficient white-goods with new generation, resource-efficient appliances is beneficial for the environment. Defining Sustainable Development In reporting on its definition of sustainable development, Bristol-Myers Squibb goes beyond the traditional one-line statement to include a comprehensive look at the all the issues that have an impact on operations and stakeholders (both local and global). BMS' overview of sustainability includes policy statements on external evaluation of EHS policies and procedures, supplier compliance, technology transfer, charitable contributions, transportation impacts, local noise and odor issues, new acquisition and divestiture processes, animal testing, pharmaceutical residuals in the environment, genomics, biosafety, and bioprospecting. Pilot Testing the Global Reporting Initiative Sustainability Guidelines The Global Reporting Initiative (GRI) is a multi-stakeholder collaboration among the Coalition of Environmentally Responsible Economies (CERES) and numerous organizations, united to develop a common framework for global sustainability reporting. Issues reported using these guidelines are not limited to environmental performance, but also include social and economic indicators. As a member of the GRI Steering Committee, General Motors is pilot testing the draft GRI guidelines in its report. Bristol-Myers Squibb, Electrolux, Proctor and Gamble and Norsk Hydro also followed some of the GRI guidelines in the preparation of their reports . Using the Pressure-State-Response Framework to Define Strategic Directions Electrolux defines its "pressures" as being the global trends of population growth, economic growth and increasing resource consumption. The environmental problems that results from these-the "states" - to which society responds through market forces, resource and cost efficiency, and regulations. These responses constitute the "driving forces to which Electrolux must respond in a responsible and proactive manner if it is to remain a leading company in the global appliance market. The Paperless Report Monsanto's report is presented exclusively as an electronic document. This is a departure from the past when these reports were been printed. For the past

several years, these have been converted into electronic presentations and made available on the Monsanto website but they were not designed specifically for Internet use. This is the first report designed specifically as an electronic presentation. There are both benefits and limitations to doing it this way. On the plus side, with the rapidly expanding use of the World Wide Web this format makes the report accessible to more people worldwide, creates a forum for sharing more information and gives access to a level of detail not available in printed versions. It has been specifically designed for web viewing with simple graphics and fast download times to make it user friendly. It also saves paper and resources and provides Monsanto with a cost-effective alternative to printing a hard-copy version. On the negative side, the report is essentially unavailable to anyone who does not own or have access to a computer. This includes most of the developing world and a large number of households in places like Canada and the US. In addition, there are certain ease-of-use benefits to a printed report. Monsanto is asking for feedback to determine how well it works before issuing the 1999 report. A Commitment to Employee Health DuPont Canada demonstrates a commitment to employee health, not only by reporting on injuries and illnesses resulting in lost time, but also by reporting on employee physical fitness levels. In its 1998 EHS report, DuPont provides data on rates of smoking, cholesterol levels, blood pressure and obesity among its employees. Benefits claims costs (as a percentage of payroll costs) are included as a EHS performance indicator. In addition, DuPont reports on the availability of on-site fitness facilities, on-site nutritional and health counselling, and health information seminars, to demonstrate the link between its policy and actions with regard to employee health. Employee Performance Indicators In 1998, for the first time, BP Amoco set global targets for its people management process. Some of these processes, such as upward feedback and personal development planning, are at the leading edge. BP also demonstrates its commitment to achieving these targets through performance measures, which are included in the report. BP Amoco reports on target attainment for key human resources activities through a number of performance indicators. They include: y y Percentage of employees receiving a performance appraisal Percentage of top leaders receiving "360 degree feedback": performance evaluations from team members, senior managers, and peers. Percentage of employees receiving 5 or more training days Percentage of employees having a "development discussion" Percentage of vacancies advertized Percentage of team leaders carrying out upward feedback

y y y y

Gender and nationality representation among graduate recruits, professional employees, and senior management

Likewise, BP Amoco also reports on its People Assurance Survey, an employee attitude survey with questions aligned closely to the company's Commitment to Employees. The survey measures overall morale, attitudes towards the company's social, financial, and environmental performance, and day-today people management, including feedback, coaching, workload and fair treatment. Stakeholder Relationship Performance Indicators BP Amoco also reports on the objective research, carried out both in the UK and internationally, which seeks the views of the public, business leaders, opinion-formers and NGOs. A 12-country study confirmed the importance of social and environmental responsibility as a factor in determining opinions about companies. BP Amoco's Global Image Tracking Survey measures the performance of BP's brand in comparison with its main competitors, which helps BP to respond to new needs and to improve the quality of its products and services. Benchmarking Corporate Environmental Management Practices In its Towards Sustainable Development report, Ontario Power Generation includes a description of the benchmarking study conducted by a consultant to compare OPG's corporate environmental management practices and processes to those of best-in-class organizations. The consultant's report affords OPG a third-party evaluation of both strengths and weaknesses in its corporate environmental practices and processes, and an essential baseline for measuring its progress. A synopsis of the findings is provided and OPG also outlines its response.

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