Process to determine material topics

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Disclosure 3-1 requires an organization to describe the process it followed to determine its material topics. Under the GRI Standards, material topics are topics that represent the organization’s most significant impacts on the economy, environment, and people, including impacts on their human rights.

The disclosure is based on impact materiality. It does not determine topics according to their financial importance to the organization, their effect on enterprise value, or their popularity among stakeholders. A double-materiality assessment can support GRI reporting only where the impact-materiality component is assessed separately and GRI material topics are selected solely according to the significance of the organization’s impacts.

The organization must explain how it identified actual and potential, negative and positive impacts across its activities and business relationships. This includes negative impacts the organization causes or contributes to through its activities and impacts directly linked to its operations, products, or services through business relationships.

The organization should describe the methods, sources, and evidence used to identify impacts. These can include economic, environmental, social and human rights impact assessments, due diligence, grievance mechanisms, audits, incident records, stakeholder information, government sources, civil-society reports, trade-union information, research and expert input.

The organization should explain the scope of its impact identification, including short- and long-term impacts and any limitations or exclusions. Where a complex value chain prevents immediate assessment of every relationship, the organization can conduct an initial scoping exercise to identify areas where negative impacts are most likely and significant. This should not be treated as a permanent boundary based only on direct control or first-tier relationships.

The organization is required to use the applicable GRI Sector Standards when determining its material topics. It must consider each topic and impact described in the applicable Sector Standards. If a Sector Standard topic is determined not material, the organization must list it in the GRI content index and explain why. Where no Sector Standard applies, the organization should explain how it considered impacts commonly associated with its sectors, products, and geographic locations.

The organization must explain how it prioritised impacts for reporting based on their significance. The significance of an actual negative impact is determined by its severity. The significance of a potential negative impact is determined by severity and likelihood. Severity comprises scale, scope, and irremediable character. For potential negative human rights impacts, severity takes precedence over likelihood.

The significance of an actual positive impact is determined by its scale and scope. The significance of a potential positive impact is determined by scale, scope, and likelihood. Positive and negative impacts should be prioritised separately, and positive impacts must not be used to offset negative impacts.

The organization should arrange its impacts from most to least significant, define and document a threshold or cut-off, and group prioritised impacts into topics. The significance of impacts is the sole criterion for determining whether a topic is material under GRI. Reporting difficulty, lack of data, absence of an existing policy, or inability to formulate a target must not be used to exclude a significant topic.

The organization must specify the stakeholders and experts whose views informed the process. Stakeholder views can help identify and assess impacts, but stakeholder concern or voting results do not replace an assessment of impact significance. The organization can identify stakeholders and experts by category and does not need to name every individual participant.

The organization should test its selected material topics against the applicable GRI Sector Standards and with potential information users and experts. It should explain significant changes made following testing or internal approval. Governance review and approval of material topics should be cross-referenced to Disclosure 2-14.

Disclosure 3-1 reports the process used to determine material topics. The final list of material topics and changes compared with the previous reporting period are reported under Disclosure 3-2.

Reasons for omission are not permitted for Disclosure 3-1. An organization reporting in accordance with the GRI Standards must report all required information under this disclosure.

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