Sustainability Reporting Guidelines: Evaluating the Transparency of Global Report- ing Initiative Reports from a Voluntary Disclo- sure and Legitimate Theory Perspective

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Sustainability Reporting Guidelines:

Evaluating the Transparency of Global

Report-ing Initiative Reports from a Voluntary

Disclo-sure and Legitimate Theory Perspective

Name: Bezemer, Kim-Katharina

Student number: s2539276

Address: Auf der Heide 25b

28355 Bremen

k.bezemer@student.rug.nl

Course: Master thesis

Study program: International Business & Management

Theme: Corporate Social Responsibility (CSR)

Supervisor: Linda Toolsema- Veldman

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Abstract

In the absence of mandatory disclosure on CSR performance it is difficult for stake-holders to determine, which companies actually perform sustainable. Since the use of sustainability reports is on the rise and is likely to continue in the future, the question to what extent these reports fulfil their initial purpose to better inform stakeholders about a company’s sustainability performance increases in importance. For this reason, the Global Reporting Initiative (GRI) was developed to provide standardized reporting guidelines to companies that engage in voluntary sustainability reporting. The GRI chal-lenges companies to report on core performance indicators for their economical, envi-ronmental and social performance as well as a balanced representation of positive and negative contributions of company performance.

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I. Table of figures

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II. Table of tables

Table 1: Anvil Knitwear measures of transparency ... 27

Table 2: KiK measures of transparency ... 31

Table 3: Mango measures of transparency ... 34

Table 4: Otto measures of transparency ... 38

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III. List of abbreviations

CSR Corporate Social Responsibility

GRI Global Reporting Initiative

UN United Nations

MNC Multinational Corporation

NGO Non-governmental organization

PI Performance Indicators

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1 Introduction

“Corporate Social Responsibility is the continuing commitment by businesses to behave ethically and contribute to economic development while improving the quality of life of the workforce and their families as well as of the local community and society at large” (World Business Council for Sustainable Development, 2000, p.3).

In the absence of mandatory disclosure of corporate social responsibility (CSR) infor-mation, it is difficult for stakeholders to determine which firms actually perform respon-sible (Mahoney, 2013). The publication of sustainability reports is not limited to com-panies that have superior CSR performance. Comcom-panies have various motives to draw up sustainability reports. Some want to communicate their superior CSR performance to stakeholders while others rather publish information to pretend commitment towards social and environmental responsibility in order to improve company image (Hahn, 2013).

The voluntary published CSR reports are known by various different names, including “Sustainability Reports”, “Environmental Reports”, “Global Reporting Initiative Re-ports” and “Citizenship ReRe-ports” (Mahoney, 2013). This paper will refer to sustainabil-ity reports or Global Reporting Initiative (GRI) reports. The Global Reporting Initiative, an organization that “promotes the use of sustainability reporting as a way for organiza-tions to become more sustainable and contribute to sustainable development” (GRI,

2014 c)defines sustainability reporting as “the practice of disclosing and being

account-able to internal and external stakeholders for organizational performance towards the goal of sustainable development. This term is used to describe reporting on economic, environmental and social impacts of a company” (GRI, 2014, p. 55).

A survey done by KPMG in 2011 found that more than 95 per cent of the largest 250 companies worldwide publish sustainability reports, a trend that is likely to continue in the future (Mahoney, 2013). This is supported by a new study conducted by the Gov-ernance & Accountability Institute (G&A) that found a drastic increase in sustainability reporting among the S&P 500 companies in 2012. According to this study, more than 53 per cent of the companies reported on sustainability issues compared to only 19 per cent

in 2010(Sustainable Brands, 2014).

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recog-nized and filled by the United Nations and their Global Reporting Initiative (GRI) in 1997. The GRI tries to “evaluate sustainability reporting practices to a level equivalent to that of financial reporting in rigor, comparability, auditability and general ac-ceptance” (Willis, 2003, p. 233) by providing a sustainability reporting framework. This framework “sets out the Principles and Standard Disclosures organizations can use to report their economic, environmental, and social performance and impacts” (GRI, 2014 d). With this framework, the GRI aims to enable greater organizational transparency and accountability to stakeholders. The usage of this framework by companies’ however, does not imply superior CSR performance but rather sets out the structure for compa-nies to report on sustainability. The idea of a globally shared framework of concepts, consistent language and metrics for sustainability reporting enabled the GRI to become “ the de facto global standard” (Hahn, 2013, p. 5). According to the study of G&A, 68 per cent of the S&P 500 companies that publish sustainability reports use GRI or GRI-References Reports (Sustainable Brands, 2014).

Due to this increase in sustainability reporting according to GRI guidelines, the interest whether GRI reports actually fulfil their mission to better inform stakeholders about the firms’ economic, environmental and social performance increases. In order for stake-holders to be better informed, the United Nations identified that “the urgency and mag-nitude of the risks and threats to our collective sustainability […] will make transparen-cy about economic, environmental and social impacts a fundamental component in ef-fective stakeholder relations” (GRI, 2014, p. 8). Therefore, this research evaluates to what extent the Global Reporting Initiative reports fulfil their mission to better inform stakeholders by portraying a transparent picture of real company sustainability perfor-mance.

That makes transparency to a central component in this paper. It can be defined as “the complete disclosure of information on the topics and indicators required to reflect im-pacts and enable stakeholders to make decisions and processes, procedures and assump-tions used to prepare those disclosures” (Boiral, 2013, p. 1038).

However, even though the GRI became “ the de facto global standard” (Hahn, 2013, p.

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pow-erful MNCs the ability to greenwash their corporate image. When reporting according to GRI guidelines, companies benefit by cooperating with the UN in sustainable report-ing without necessarily performreport-ing sustainable. Further, by voluntarily publishreport-ing in-formation in sustainability reports that lack accountability, it is likely for companies to disclose information that shed a positive light on the company.

So according to the criticism, companies report according to the GRI guidelines, how-ever, not always in a transparent manner as required by the Global Reporting Initiative. Even though it is widely accepted that the GRI has helped to improve the rigor of sus-tainability reporting, the degree of accountability and transparency of GRI reports re-main controversial (Boiral, 2013).

The omission of important information in sustainability reporting will be referred to as “reporting-performance portrayal gap” in this research, when a company report does not reflect company sustainability performance in a transparent way.

Therefore, this research aims to checkthe accuracy of criticism towards the Global

Re-porting Initiative with regard to transparency of GRI reports by answering following research question:

To what extent do the “Global Reporting Initiative” reports of a company portray a transparent picture of real company sustainability performance?

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That way, this thesis will contribute to the quality of sustainability reporting by detect-ing issues the GRI reports and GRI guidelines face in the apparel industry and further by providing recommendations to the guidelines in order to improve the quality of sus-tainability reporting.

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2 The Global Reporting Initiative

The GRI, founded in 1997 is intended to provide a generally accepted framework for organizations that report on their economic, environmental and social performance. A sustainability report should, according to the GRI “provide a balanced and reasonable representation of the sustainability performance of a reporting organization- including positive and negative contributions” (GRI, 2014, p.3). The GRI therefore requires that sustainability reports reflect a transparent picture of sustainability performance of the reporting organization. This is of interest to a wide range of stakeholders, namely “busi-ness, labour, non-governmental organizations, investors, and accountancies” (GRI, 2014, p.2). Therefore, the GRI collaborates with experts from various stakeholder groups that represent individual interests to ensure a continuously improvement of the reporting framework and the transparency of reporting since it is founding in 1997. The sustainability reporting guidelines represent the cornerstone of the framework by providing standard disclosures and sector disclosures made up of performance indica-tors, the PIs (Proving and Improving, 2014). These performance indicators are measures used by companies to compare performance on various activities, here sustainability performance. The PI’s have indicator protocols, which provide definitions, compilation guidance and other information to “ensure consistency in the interpretation of the Per-formance Indicators” across organizations (Proving and Improving, 2014).

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are referred to SO and finally performance indicators about product responsibility are referred to as PR. Another distinction is made concerning performance indicators. 50 out of the 79 PI are core performance indicators, meaning these indicators are “of inter-est to most stakeholders and assumed to be material unless deemed otherwise” (GRI, 2014 e). The additional indicators represent “emerging practice or address topics that may be material to some organizations but not generally for a majority” (GRI, 2014 e). With these guidelines, the GRI aims to provide a “trusted and credible framework for sustainability reporting that can be used by organizations of any size, sector, or loca-tion” (GRI, 2014, p.2). Instead of only providing guidelines, the GRI requires organiza-tions that report according to GRI guidelines to do that in a transparent manner by in-cluding positive and negative contributions of the organization.

2.1 Application Levels

The GRI further developed application levels to which, “upon finalization of the report, preparers should declare the level to which they have applied the GRI reporting frame-work via the “GRI Application Level System” (GRI, 2014, p.5). This declaration aims to communicate to which degree the reporting framework has been applied in the prepa-ration of the report. In order to categorize the sustainability reports, the GRI developed three levels, A, B and C. The reporting criteria included in the graph reflect the cover-age of the GRI reporting framework.

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Focusing on performance indicators and sector supplement PI, the last row of the graph, enormous differences between the lowest application level C and the highest application level A. When a company self-declares the reporting level C, the report must include information on at least 10 performance indicators, including at least one from each di-mension (economic, environmental and social). In contrast, to be able to declare the highest application level, the report of a company must contain information on all core performance indicators and sector supplement indicator either by reporting on the indi-cator or by explaining the reason for its omission. Therefore, a company declaring the highest application level to its sustainability report is expected to fulfil the requirements developed by the GRI.

To be able to declare a “+” to the sustainability report at each application level, an or-ganization has to utilize external assurance like use of professional assurance providers or stakeholder panels (GRI, 2014). So, the GRI “uses the term external assurance to refer to activities designed to result in published conclusions on the quality of the report and the information contained within it […] this is different from activities designed to assess or validate the quality or level of the performance of an organization” (GRI, 2014, p.41).

To sum up, an organization can self-declare the reporting level on its own assessment by comparing in how far the report content is in compliance with the criteria in the GRI application level regardless of the level of sustainability performance of a company. In this research, only companies that declare the highest application level to the sustain-ability report are being analysed.

2.2 Sector Guidance

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in-Apparel and Footwear, Construction and Real Estate, Electric Utilities, Event Organiz-ers, Financial Services, Food Processing, Media, Mining and Metals, NGO and Oil and Gas (GRI, 2013).

Since this study focuses on sustainability reports from the apparel industry, only the sector supplements from the Apparel and Footwear sector are taken into account in this study, which contain 34 Performance Indicators. Due to an international expansion of the apparel industry, the sector is characterized by a complex relationship between the various entities in different countries and by global supply chains (GRI, 2014). An in-creasing understanding emerged from stakeholder perspective that companies are re-sponsible for the conditions under which products are being produced in the supply chain, especially in countries where fundamental rights and protections are not neces-sarily provided by law or adequately enforced. Here, each company develops its own Code of Conduct that outlines the responsibility of proper production practices for the concerned company and its suppliers. However, control in production countries remains expensive and complicated to conduct, therefore the Apparel and Footwear Sector Sup-plements concentrate on working conditions and environmental practices throughout the complex supply chains (GRI, 2014, p. 9).

In addition to the complexity of supply chain control, other broad macro-economic trends shape the apparel sector like the rapidly changing demand for products. This re-sults in “buying practices which can intensify a number of sustainability challenges fac-ing the sector, includfac-ing unpaid or excessive overtime, pressure on wages, and the hir-ing of temporary workers on temporary contracts and use of migrant” (GRI, 2014, p. 9). 5 major issues in the industry have been identified, namely supply chain standards, use of materials and energy, wages and hours of employees, labour and management rela-tions and community investment strategy (GRI, 2014 b) that current GRI guidelines do not adequately address.

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2.3 Reporting Boundary

When defining the content for a report, an organization further needs to determine which entities will be included in the sustainability report (GRI, 2014). “The approach to reporting on an entity will depend on a combination of the reporting organization’s control or influence over the entity, and whether the disclosure relates to operational performance” (GRI, 2014, p.17). Also, “entities with significant impacts typically gen-erate the greatest risk or opportunity for an organization and its stakeholders, and there-fore are the entities for which the organization is most likely to be perceived as being accountable or responsible for” (GRI, 2014, p.17). For the apparel industry it is true that suppliers who produce the goods have the most significant impact. This is also why the Apparel and Footwear Sector Supplements put a major focus on the supplier and their performance. Therefore, it can be argued that it is of vital importance in the textile in-dustry to include the performance of suppliers in the sustainability report. However, due to the complexity of the supply chains and its global distribution it is also more difficult to include the performance of suppliers in the sustainability report.

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3 Literature Review

When looking at previous research that has been done in this field, it stands out that the relationship between sustainability performance and reporting practice has been increas-ingly debated in literature (Boiral, 2013).

Hahn and Kühnen (2013) published a literature review that takes into account all litera-ture published from 1999 until 2011 about sustainability reporting. A review of 178 articles from journals related to business, management and accounting allowed them to identify what “determinants of sustainability reporting are examined in the literature” (Hahn, 2013, p. 5), to identify gaps and opportunities for future research. Even though sustainability reporting has gained importance in business and experienced a strong growth in empirical research, the quantity of literature available is still limited (Hahn, 2013). The authors identified a focus on determinants of sustainability reporting, while there are major shortcomings in other fields such as reporting quality or stakeholder perception (Hahn, 2013). Only a few studies examine the reporting quality of sustaina-bility reports even though it is of major importance to know whether these reports pro-vide a transparent picture of the sustainability performance of a company. Therefore, this study focuses on the issue of reporting quality.

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quality of information disclosure, however problems with voluntary disclosure of in-formation still exist (Criado-Jiménez, Chulián, 2008).

Since this study focuses on voluntary disclosure of sustainability information, a research carried out by Boiral (2013) on the quality of sustainability reports will be considered. Boiral (2013) used the concept of simulacrum, “the artificial representation of reality as conveyed by images to control social representations” (Purdue University, 2014), which was proposed by Baudrillard in order to determine “the degree to which the representa-tions in the reports are disconnected from the reality of business impacts” (Boiral, 2013, p. 1037). By analysing the pictures from reports of the energy and mining sectors, the author found that more than 90 per cent of the reports lack the principles of GRI in terms of quality, balance and completeness and hence reflect a wrong company image (Boiral, 2013).

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steps description of negative event and explanation to provide the reader with relevant facts. The latter, consist of the steps evaluate the incident and which actions have been taken by the company. With this scheme, Hahn and Lülfs (2013) try to provide a tool that fosters transparent reporting of negative events that according to his findings is cur-rently not given.

The reporting performance portrayal gap was used in a study by Adams (2004) as a key measure to which an organization is accountable to its stakeholders. The author ana-lysed the 1993 and 1999 reports of a case study company “Alpha” to evaluate “the ex-tent to which corporate reporting on ethical, social and environmental issues reflects

corporate performance”(Adams, 2004, p. 731). This examination allows Adams (2004)

to get an insight on the extent to which a company fulfils its duty of accountability to stakeholders. Adams (2004) identifies the lack of completeness in reports the most seri-ous problem and tries to address this issue in her research. With the counter accounting approach, she intended to give “an indication of the extent to which stakeholders can rely on corporate reporting as a means of assessing corporate performance” (Adams, 2004, p. 731). Here, the focus lies on the voluntary guidelines of the Institute of Social and Ethical AccountAbility (AA1000 standards), the Global Reporting Initiative and the chemical industry. Her findings lead to the conclusion that the two reports “do not demonstrate a high level of accountability to key stakeholder groups on ethical, social and environmental issues” (Adams, 2004, p. 731).

The findings of Holder-Webb (2009), Criado-Jiménez (2008), Boiral (2013), Clarkson (2011) and Adams (2004) all have the same tendency, independent from sample size, research year or national setting: the reports analysed lack fundamental information on company performance and therefore do not provide a transparent picture of company performance.

3.1 Voluntary Disclosure and Legitimacy Theory

“There are several theories that consider the association between voluntary CSR disclo-sure and CSR performance” (Mahoney, 2013, p. 351), which are generally consistent with either a voluntary disclosure perspective or a legitimacy theory perspective.

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green-washing?” is helpful. Mahoney (2013) attempted to understand “whether U.S. firms issue standalone CSR reports as a substantive signal of concern for society and the envi-ronment, or alternatively, whether standalone CSR reports are issued in an attempt to legitimize firms’ concerns for social and environmental issues” (Mahoney, 2013, p. 351). So in this research, Mahoney tries to evaluate firms’ motivations for voluntarily issuing sustainability reports.

According to the voluntary disclosure theory, firms issue sustainability reports to ensure that stakeholders are informed about the companies’ commitment towards sustainability performance and are aware of the appropriateness of firms’ actions (Mahoney, 2013). This enables the companies to differentiate themselves from poor performing competi-tors on the market and hence achieve competitive advantage by improving their corpo-rate image and reputation (Boiral, 2013). A study conducted by Clarkson found that companies with better environmental performance tend to make more extensive disclo-sure in their sustainability reports than poor performing competitors. (Li, Clarkson, 2006). So, the voluntary disclosure theory states that companies with superior sustaina-bility performance have an incentive to publish sustainasustaina-bility reports to inform stake-holder about their commitment.

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com-It follows that the disclosed information on environmental and social performance in-tends to promote “an impression of legitimate social and environmental values” (Ma-honey, 2013, p. 352) that do not necessarily reflect real company values or performance. So, the legitimacy theory states that companies publish sustainability reports that do not necessarily reflect real company performance as a result of external pressure to improve company image.

Going back to the study of Mahoney (2013) and his evaluation of firms’ motives for publishing sustainability reports, he found that firms that voluntarily issue standalone CSR reports generally have a higher CSR performance, which suggests that firms are using these reports to communicate stronger social and environmental performance to stakeholders (Mahoney, 2013). Hence, the study found support for the voluntary disclo-sure theory and refutes the legitimacy theory.

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4 Conceptual Framework

Since this research tries to evaluate the transparency of Global Reporting Initiative re-ports, a comparison between the reporting practice (sustainability reports) and the sus-tainability performance of a company must be made. This comparison is made with the help of two different approaches, a content analysis and a counter accounting approach. With these approaches, it can be determined whether a sustainability report of a compa-ny portrays a transparent picture of compacompa-ny performance or whether it portrays a porting performance portrayal gap, meaning that the sustainability report does not re-flect real company sustainability performance.

Figure 2: Conceptual framework Source: own illustration

Following sub-questions are answered during the research in order to evaluate the trans-parency of sustainability reports:

1. Does the company report on all (core) performance indicators relevant to its op-erations as defined by the Global Reporting Initiative?

2. Does the company include the Apparel and Footwear Sector Supplements in its sustainability report as intended by the Global Reporting Initiative?

3. Are (all) negative aspects or events of a company’s performance completely dis-closed in the sustainability report?

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per-formance indicators in the report. Therefore, a content analysis of the sustainability re-port is conducted in order to evaluate whether a company actually rere-ports on all core performance indicators as implied by the highest application level.

The second sub-question also addresses the requirements developed by the GRI for sus-tainability reports to achieve the highest application level. Here, the content analysis evaluates whether a company includes all Apparel and Footwear Sector Supplements relevant to its operations in the sustainability report.

Sub-question three addresses the claim of the GRI that a sustainability report must “provide a balanced and reasonable representation of the sustainability performance of a reporting organization- including positive and negative contributions” (GRI, 2014, p.3). So, the GRI further requires companies to report positive as well as negative contribu-tions of company performance in addition to the performance indicators and sector sup-plements. Therefore, the last question involves the inclusion of all negative events that occurred in the reporting period in the sustainability report. A report is searched for negative events during the content analysis. When all negative events in the sustainabil-ity are identified, an additional step is necessary to be able to answer the question. A counter accounting approach has to be conducted where external sources are being searched for information on negative performance of a company. The information ob-tained from external sources is then compared to the information provided by the com-panies in the sustainability report. With this comparison, the question whether all events are completely displayed in the sustainability reports can hence be answered.

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5 Methodology

The collection of data is centred on firms in the apparel industry. This sector was chosen based on the extent of sustainability-development issues it faces, the occurring trend of a fast fashion industry accompanied by decreasing price levels and the availability of sources given.

One of the widest discussed issues in the apparel sector occurred in 1996 where it was revealed that Nike used child labour in its production of soccer balls in Pakistan (Busi-ness Insider, 2013). After those accusations, company image drastically declined. Nike reacted by engaging in various initiatives and hence managed to turnaround their com-pany image by creating the Fair Labour Association and by being the first one in the sports brand industry to publish a corporate social responsibility report with over 100 pages (Business Insider, 2013) according to GRI guidelines. With these initiatives and received certificates, Nike was able to convince its customers and stakeholders of its changing and now sustainable work practices. Another example in this sector occurred in 2006 where according to a National Labour Committee report an estimate of 200 children (11 years old and younger) were found sewing clothes for Wal-Mart, Puma and GAP at a factory in Bangladesh. This factory was even certified by the U.S. apparel industries’ Worldwide Responsibly Apparel Production (WRAP), which signals a

fail-ure in corporate monitoring throughout the supply chain in various companies (Labour

and Worklife, 2014).

A recent example occurred in 2014, affecting a company under consideration in this research. In September, the factory Ali Enterprises in Karatschi burned down, a major supplier of the German company KIK. It was one of the severest accidents in the appar-el industry in Pakistan where 254 people died, which could be attributed to fatal security

breaches of the factory (Spiegel Online, 2014 a).

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5.1 Sample size

To narrow down the study and sample size, only companies that report according to the GRI guidelines and that achieved the application level A or A+ are being selected. In theory, this application level contains the reports with the highest quality and transpar-ency that further address all core indicators in the GRI guidelines (Boiral, 2013) as well as the Apparel and Footwear Sector Supplements. The reports are available free of

charge at the database of the Global Reporting Initiative (GRI, 2014 a). The sample is

collected by looking at all companies in the textile and apparel industry that published GRI reports in the year 2011, which are 38 in total. Out of these 38 reports, only seven reports have declared the highest application level (see Appendix 03). Due to a time lag between one or two years that exists between the year covered by a report and the date the report is released (Boiral, 2013), the reports published in 2011 partly cover company performance in year 2010 (5 companies), while two reports cover the reporting period 2011.

5.2 Content analysis

According to definition, a content analysis is an “analysis to determine the meaning, purpose or effect of any type of communication, as literature, newspaper or broadcasts by studying and evaluating the details, and implications of the content” (Dictionary, 2014).

In this research, five sustainability reports are the type of communication that is ana-lysed to determine its content in regard to companies’ sustainability performance. In-stead of evaluating details and implications of the content, this analysis focuses on the information provided to each core performance indicator. In total, there are 50 core per-formance indicators a company should provide information on in the sustainability re-port on the “economic, environmental and social performance of the organization” (GRI, 2014, p. 13).

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partially or completely in the sustainability report while collecting information about negative events included in the sustainability report. The performance indicators and sector supplements are then assigned to the adequate category: Not reported, partially reported or fully reported.

The GRI claims that sustainability reports needs to include information on all core per-formance indicators and sector supplements or reasons for their omission to declare the highest application level. PI and sector supplements that are indicated in the GRI con-tent index as confidential information are classified as fully reported in the concon-tent analysis. This mainly concerns information on economic performance indicators but is rarely the case in this research. Information that is stated as not relevant to the organiza-tion is more critical to assign to one of the three categories. With the claim “not rele-vant”, a reason for omission of the PI is provided and since the indicator is not relevant to an organization it cannot be measured and therefore reported, so it is assigned to fully reported. Nevertheless, further reasoning on why the indicator is not relevant to the re-porting organization is desirable. However, a relevant factor here is the rere-porting boundary. When a company includes its suppliers performance in the report, more PI become relevant to the organization but when an organization excludes its suppliers from reporting, more PI become irrelevant to the performance of the organization. Therefore, the analysis explicitly states whether a company includes its suppliers in the report or not. This inclusion however signals higher commitment towards sustainability reporting.

In case a company claims that more information on the performance indicator will be provided in future reports, it depends on the extent of information provided in the cur-rent report whether the PI is classified as partially or not reported.

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5.3 Counter accounting

Counter accounting activities are “constituted by information and reporting systems employed by groups such as NGOs with a view to promoting countering prevailing of-ficial positions” (O’Sullivan, O’Dwyer, 2008, p. 555). This approach is necessary to overcome the prevailing position that companies publishing sustainability reports also perform sustainable. It helps to evaluate the transparency of sustainability reports on the basis of negative events included in sustainability reports. Boiral (2013) defines this approach as “process of identifying and reporting information on organizations’ signifi-cant economic, environmental and social issues that comes from external or unofficial sources” (Boiral, 2013, p.1037). For this purpose, external sources are searched for neg-ative information on every company under consideration. A critical step here is to iden-tify the relevant sources that need to be searched for information and not to miss any. Therefore, 2 main types of online information sources are used: international and local newspaper articles, online magazines, websites of NGOs like Clean Clothes Campaign or Greenpeace and websites of NGOs that also use the counter accounting approach like Corporate Watch or Consumer International. Other relevant sources identified include databases of the “Textilwirtschaft” and International Labour Rights Forum.

All negative events identified must fulfil following criteria:

(1) Address significant events that occurred in 2010/2011, implicating the re-sponsibility of one of the 7 firms

(2) Concerns a sustainable issue that is covered by one or more of the Global reporting Initiative performance indicators

(3) Must come from two independent, reliable sources with well-documented facts

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These key words are listed in 9, in the excel column “negative events reported” and in-clude all terms used by the company itself.

However, not only negative information extracted from the sustainability report is used to search for information on company performance in external sources. Every Internet search included the concerning company name and reporting year to make sure the cri-teria for external sources are being met. The company name and reporting year is then complemented by either production countries, initiatives signed by the company, certain products or terms like wages, chemicals, work councils, waste, working conditions and other general terms concerning performance indicators that have been identified as criti-cal to the apparel industry by the GRI in the section sector supplements.

All sources and events identified that also fulfil the 3 criterions are then summarized in a table (see Appendix 11). In a next step, these events are being compared with negative events included in the sustainability report to see whether the company actually disclos-es all negative events in the reporting period in the sustainability report. The negative events the company completely fails to include in the report are then categorized under the category “not reported”. Events that are rather mentioned in the report without providing further information are categorized as “partially reported” and the events that are fully disclosed in the sustainability report are assigned to the category “fully report-ed”. However, in some cases information about a negative event provided by the com-pany in its sustainability report cannot be verified by external sources, meaning no in-formation on this event can be found. Here, this event is considered as fully reported since more information can be obtained from the company report itself than from exter-nal sources.

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5.4 Transparency vs reporting-performance portrayal gap

All three requirements, namely the PI, Apparel and Footwear Sector Supplements and negative events are assigned to one of the following categories: not reported, partially reported, and fully reported. This allows measuring the level of transparency for each of the sustainability reports separately. The higher the number of PI, sector supplements or negative events assigned to the category “not reported”, the lower the level of transpar-ency. A lower level of transparency indicates a reporting-performance portrayal gap since the information disclosed in the report is not congruent with the information ob-tained from external sources. This means that the GRI report does not reflect real com-pany performance in terms of sustainability and is therefore likely being used as a tool to improve company image or ensure that their activities are perceived as legitimate by outside parties (Cho, 2012). This could indicate that the company discloses information in the sustainability report as a reaction to external pressures and therefore follows the

legitimacy theory. Regardless of the motive for publishing a sustainability report, a high

amount of PIs, sector supplements or negative events assigned to the “not reported” category questions the effectiveness of application levels of the GRI. This means that without fulfilling the requirements developed by the GRI, a company can simply claim to report according to the highest application level A without actually doing so. This would hence reinforce the criticism voiced towards the Global Reporting Initiative in terms of accountability.

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5.5 Interviews

The previous sections evaluate to what extent a company’s sustainability report portrays a transparent picture of real company sustainability performance. During the analysis, the number of performance indicators, sector supplements and negative events every company fails to include in the sustainability report are identified.

Based on these findings, questions are developed that address the issues identified dur-ing the analysis. With a high number of PIs, sector supplements or negative events not disclosed in the reports, these issues include the effectiveness of the application level, the sustainability reports in general and other issues identified during this research. For this purpose, the questions are answered in interviews with experts from the apparel industry that specialized in the area of CSR and supply chain management. These ques-tions aim at detecting the reason for omission of certain performance indicators or sec-tor supplements and how to improve reporting on these indicasec-tors by giving recommen-dations.

5.6 Limitations

The limitation of this research is first of all its generalizability. The findings of this study are sector specific, and therefore cannot be transferred to other industries or even companies that report according to the GRI guidelines. Further, reports are selected ac-cording to application level and year published, this means that future reports of the

same company can provide a completely different picture.However, what can be

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excluded since the report is not available online, neither in the GRI database nor on the company website itself. Upon request where to find the sustainability report of 2010/2011 online, the company assured to sent the report via mail, however, no report arrived till today.

Another limitation lies in the collection of data. The counter accounting approach is crucial here since enough data about the five companies under consideration must be found to be able to properly evaluate whether the sustainability reports are transparent or whether they present a “reporting-performance” portrayal gap. In order to ensure all relevant data is found on the performance of the selected companies, various databases and online platforms of organizations from the apparel industry are selected and searched. However, one company in the sample size (Mango) is headquartered in Spain

and therefore some information about the company’s negative events is in Spanish.For

linguistic reasons, only English and German articles are taken into consideration during the counter accounting approach. Therefore, it is possible that some information, espe-cially on the company Mango, might be missing.

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6 Analysis

This section presents the findings of this research for every company separately. First, general information about each company and its sustainability report is given like re-porting format, number of reports published and rere-porting boundary.

In a next step, the findings of the content analysis are presented. Here, the number of performance indicators and sector supplements a company fails to disclose are de-scribed as well as negative information included in the report. This is, in a next step, compared to the negative information obtained from external sources. That way, the transparency of sustainability reports can be evaluated. Based on these findings, an indi-cation about the motive for publishing sustainability reports can be given for each pany. Each company is displayed and evaluated separately, since the findings are com-pany specific and cannot be generalized for the entire industry. At the end of this sec-tion, the overall findings are being presented.

6.1 Anvil Knitwear

Anvil Knitwear is a fashion company headquartered in New York that focuses on gar-ments. According to the companies’ website, they were one of the first ones in the in-dustry that used organic cotton and recycled P.E.T. apparel and “incorporated social and environmental practices that include a lasting commitment to the Environment, People and Communities” (Anvil Knitwear, 2014).

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change) with the reason of confidentiality of financial information. So the only perfor-mance indicators the company fails to disclose without providing reasons for its omis-sion covers the aspect remediation, HR11 (number of grievances). The 3 indicators that are only partially reported by Anvil lack some information required by the G3 Guide-lines. Here, this covers aspects of biodiversity (EN11), material spills (EN23), and the formal system by which reusing and recycling of materials is quantified (EN27) (see Appendix 4).

Turning to the Apparel and Footwear Sector Supplements, Anvil includes the first sec-tion of sector supplements namely the supply chain standards. This secsec-tion contains 12 supplements the company fully discloses at the end of the sustainability report. No rea-sons for the omission of other sector supplements are provided to the reader.

Turning to negative events mentioned in the report, Anvil starts its report with a 2010 overview from the sustainability team with the words “We’ve some good news and some bad news” (Anvil Knitwear 2011, p. 4). Here, the company clearly states that due to a high production level in year 2010, overall companies’ emissions went up which is the opposite of what the company wanted to achieve. This increase in production also resulted in an increase in outgoing third party emissions, an increase in material utiliza-tion and ground water usage. This means the very start of the report already covers the first negative event of three in total.

However, there are other negative events included in the report like the non-compliance of suppliers with overtime standards in four cases and some major and minor compli-ance in the auditing process, which account for the second negative event included in the sustainability report. According to the report, the majority of the non-compliance findings can be categorized under Environmental Matters and Health and Safety issues, which are being followed up according to the report. The last negative event covered by the report includes AnvilRecycled totes that were made of wrong material. According to the report, Anvil discovered that their totes were made from cotton left over from the ginning process and not pre-consumed clippings as promised by the company.

The next step is to look at external sources like databases and journals to find

infor-mation about the companies’ performance in 2011. However, when looking at these

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even is fully reported by the company (Sustainable Brands, 2011). Concerning the other two negative events included in the sustainability report, no external sources fulfil the criteria developed in the methodology. Since more information on these events is hence provided by the company itself than can be obtained from external sources, these events are considered as fully reported by Anvil Knitwear.

Table 1: Anvil Knitwear measures of transparency Source: own illustration

What can be concluded from these findings is that Anvil Knitwear’s sustainability re-port 2010 is transparent on all three levels measured. The company rere-ports on nearly all PI and sector supplements or provides explanations for their omission. Further, the company fully reports on all negative events identified which means that the report por-trays a transparent picture of real company performance by displaying a balance of posi-tive and negaposi-tive events. With the question and answer reporting format and additional-ly, the usage of some sector supplements, the report is a prime example for the highest application level of the Global Reporting Initiative. This indicates that Anvil Knitwear has a superior sustainability performance and aims at signalling this to its stakeholders. This finding may indicate that Anvil Knitwear follows the voluntary disclosure theory as motive for publishing sustainability reports.

Fully reported Partially reported Not reported

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6.2 KiK

“KiK Textilien und Non-Food GmbH” is a German textile discount founded in 1994 that became one of the ten biggest providers in the German retail sector with 2.600 branches in Germany and 21.000 employees (KiK, 2014). The company advertises with low prices and promises “every customer can fit out oneself with a new set of clothes for less than 30 Euro” (KiK, 2014). These discount clothing retailers are widely criti-cized and have a poor public image when it comes to sustainability. This might be one

of the reasons why KiK startedpublishing its first sustainability report in 2010

accord-ing to G3 Guidelines of the Global Reportaccord-ing Initiative. This report is limited to the ac-tivities of the KiK Textilien und Non-Food GmbH Deutschland, KiK Logistik GmbH and European subsidiaries outside Germany, so the supplier performance is not taken into consideration. The report is divided into eight sections, namely company profile, strategy and management, open dialogue, suppliers, products, sites, employees and facts and figures. There is a GRI content index at the end of the report that indicates in what section the information on the specific performance indicator can be found. The reader is hence obliged to go through an entire section (up to 12 pages) to look for the desired information.

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Coming to the amount of sector supplements the company includes in the sustainability report, none can be identified. This means that KiK does not report on any sector sup-plement and does not provide any reason for their omission.

When looking at negative events included in the sustainability report, the third section of the report has to be considered in more detail. In the “open dialogue” section, Manag-ing Director CSR Dr. Michael Arretz talks to Thomas Schwarz, Head of International Communication at CARE Deutschland-Luxemburg e.V., a non-profit organization that supports poor and disadvantaged groups (Care, 2014). It opens with a quote of Dr. Mi-chael Arretz, “we’re being open and reporting on our activities” which aims at address-ing the concerns of critics and show corporate responsibility (KiK, 2010, p. 18). One of these critics is Thomas Schwarz who clearly expresses his concerns about poor working conditions in Germany and Bangladesh, no equal wages for men and women and KiK’s poor public image within the open dialogue section (KiK, 2010, p.18). According to Schwartz “Real mistakes have been made while, at the same time, KiK has made a lot of money. So there are some very good reasons why you [KiK] have such a poor public image” (KiK, 2010, p. 19). Dr. Michael Arretz comment on these allegations “that’s a perception I come up against time and time again […]. This discount clothing business is viewed extremely critically” (KiK, 2010, p. 19). He further admits, “KiK is a young company and, over the course of growth, errors were made” (KiK, 2010, p. 20). How-ever, he advertises with the change KiK has made since 2007 with the introduction of a Code of Conduct, minimum wage or the recently established standalone CSR manage-ment and states “we’re on the right track” (KiK, 2010, p. 20).

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can be found elsewhere in the previous sections of the report, only references are given to tables and figures in the appendix.

The findings from the content analysis alone already signal that there are big reporting gaps in the sustainability report of KiK by disclosing negative information only in the appendix of the report and by the failure to disclose 20 PI partially or completely. Next, the negative events included in the sustainability report are compared to information provided in the counter accounting approach. In total, there are 9 negative events identi-fied from external sources from which 7 are not included in the report and 2 partially. In 2010, a German TV channel broadcasts a documentary “ARD-Exklusiv: Die KiK

Sto-ry” which reveals critical working conditions in German branches but also in production

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was accused of staffing their stores with part-time employees, not represented by un-ions, without employment contracts who, before 1 October 2010, worked at low wage (DW, 2010). Also, negative events are identified that concern working conditions in the production country Bangladesh. Here, journalists found under aged children working in factories that produce for KiK and interviewed seamstresses who earn 25 Euro a month while working 9 hours a day, an issue that is clearly forbidden by the Code of Conduct signed by KiK and all its suppliers (Norddeutscher Rundfunk, 2010). Another 2 nega-tive events not included in the sustainability report by KiK.

By comparing the negative events in the report and the events obtained from external sources, it becomes visible that KiK does infuse some of the negative events partially reported in the sustainability report, however, present this information in a rather differ-ent way. One example here is the introduction of the minimum wage: “when it comes to wages, we set a clear example for the clothing industry when we became the first cloth-ing discounter to introduce a basic wage on 1 October 2010” (KiK, 2010, p. 56). Here, no information is given on legal proceedings against the company for wage dumping or the introduction of the minimum wage as a result of external pressure. Another example is the high percentage of trainees the company advertises with. According to external sources, trainees are being employed because of cheap labour, the reports states “with around 10 per cent of our workforce made up of trainees, we rank among the top Ger-man companies […]. Training our young employees, supporting them and helping them achieve management positions is a principle that we have pursued since we went into business” (KiK, 2010, p. 58).

Table 2: KiK measures of transparency Source: own illustration

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To conclude, the counter accounting approach confirms the tendency that already be-came apparent in the content analysis. KiK’s sustainability report reveals massive re-porting gaps in terms of all three measures. The company fails to disclose 20 out of 50 core PI partially or completely, does not include any sector supplement and discloses none of the 9 negative events completely in its sustainability report. Rather, 7 negative events are not reported at all, while 2 are being partially reported. Therefore, the sus-tainability report of KiK does not provide a balanced picture of company performance and fundamentally lacks transparency. These findings indicate that KiK publishes the sustainability report because of the motivation to ensure their activities are perceived as legitimate by outside parties since the discount clothing business is widely criticized. Further, the company aims to improve company image with stakeholders and change the prevailing perceptions of stakeholders about the company. These findings could hence provide support for the legitimacy theory.

6.3 Mango

Mango is a Spanish fashion distribution chain, headquartered in Barcelona that opened its first store in 1984. Since then, Mango expanded first on national basis and in 1992 on international basis. Today, Mango employs more than 13.000 people and has 2.415 stores in 107 different countries (Mango, 2014).

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When conducting the content analysis of the Mango report, it becomes clear that the company fails to report on 20 of the core performance indicators completely, while 7 performance indicators are only partially reported (see Appendix 07). This great number of indicators the company does not disclose in the report contradicts with the highest application level Mango declared since it requires a complete disclosure of all core per-formance indicators. Most indicators the company fails to report on are environmental aspects, which include water sources affected (EN9), impacts of activities and products on biodiversity (EN12), indirect greenhouse gas emissions by weight (EN17) and NO SO and other significant air emissions by type and weight (EN20). The indicators that are only partially reported also include mainly environmental aspects like initiatives to mitigate environmental impacts of products (EN27) or significant environmental im-pacts of transporting products (EN29).

In the 2010 sustainability report by Mango does not include any sector supplement nor reasons for their omission.

When looking at negative aspects that are included in the report, only 2 events can be identified that occurred in financial year 2010. The first one is a table that contains the number of incidents with substances (Cadium, Azoic dyes, phenolic compounds, chro-mo, formaldehyde and lead) found in garments or accessories. The second negative event included in the report is a table that contains information on breaches of the code of conduct in financial year 2010. According to Mango, these breaches include issues like requesting greater detail in certain documents, the automatization of certain pro-cesses, cleanliness and order in certain areas of the production plant. In total, 43 breach-es of the Code of Conduct are being reported, however, no further information is given (Mango, 2010, p. 47). So, what can be concluded from the content analysis is that the Mango report fails to include information on various core performance indicators, espe-cially in terms of the environmental performance of the company and further, the report does not include many negative events in the report.

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International, 2014). Even though NPE does not constitute any direct health risks, these chemicals have a range of hazardous effects on human health and other organisms when released into the environment (Greenpeace International, 2014). Mango stated in the report that substances were found in garments, however, assured that these products have not been offered to sell, so this event is categorized as partially reported.

A second negative event found was the accusation that sandblasting is still used in the production of jeans. Even though this technique was banned because it was proven to cause fatal lung diseases, and various brands officially deny using this technique, in-cluding Mango, it is still commonly used in the production process (Clean Clothes Campaign, 2012). Since Mango does not include any information on the production of jeans in its sustainability report, is it considered as not reported. The breaches of the code of conduct as described by Mango could not be identified by external sources that fulfil the criteria developed, therefore this event is also considered as fully reported by the company itself.

Table 3: Mango measures of transparency Source: own illustration

To summarize, Mangos sustainability report fundamentally lacks core performance in-dicators and all sector supplements. In case negative events are included, the infor-mation provided is not sufficient to enable stakeholders to make decisions as required by the definition of transparency. This indicates that Mango aims at improving the per-ceptions about company performance without disclosing much information on the firm’s environmental or social record and thereby providing support for the legitimacy theory. Even though only two negative events are identified from external sources, which are even partially disclosed in the sustainability report, Mango does not seem to

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provide a transparent picture of company performance and therefore, a reporting-performance portrayal gap also exists for the Mango sustainability report.

6.4 Otto

The Otto Group is a German family owned holding that incorporates various companies and brands like Baur, Bonprix, Heine, Hermes, Otto, Schwab and SportScheck. The company was founded in 1949 and today employs more than 53.000 people in 123 sub-sidiaries in more than 20 countries (Otto Group, 2014).

Otto publishes sustainability reports since 2009, every two years, and is perceived as one of the leading German sustainable companies that incorporate sustainability throughout their entire company for years. Dr. Michael Otto, member of the Otto fami-ly, is awarded by many organizations for his exceptional involvement in economical and social activities. The Otto Group’s Corporate Responsibility Report 2011 is pub-lished according to G3 Guidelines of the Global Reporting Initiative, contains eleven companies and is structured “based on the Otto Group’s five CR fields of action: Em-ployees, Climate and Environment, Suppliers, Assortment and Customers and Society” (Otto Group, 2011, p. 3). However, the report is limited to the activities of the 11 brands and does not include suppliers in the reporting boundary. A GRI content index at the end of the report indicates where information can be found. In some cases, only one or a few pages are indicated, however, sometimes the index refers to more than 20 pages for a specific performance indicator. This obliges the reader to go through many pages in order to find the information needed. Since the report contains information on eleven companies, it is not surprising that it is one of the most extensive ones analysed in this research.

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In the sustainability report of the Otto Group, again, no sector supplements are being included and no reasons for their omission are being provided.

When looking at negative events, there are 6 events included in the Otto Group sustain-ability report (see 110). These events include an incident of live plucking, the legal dis-putes due to anti-competitive behaviour which relate to wrong “Stiftung Warentest” claims, which is a German consumer organization that investigates goods and services, and violations of customer data. Another event is the reduction in workforce during 2011 and further, 4 product recalls have been made. Also violations of standards by suppliers in the areas of documentation, health and safety regulations, maximum work-ing hours and wages are mentioned in the sustainability report (Otto Group, 2011). With 6 negative events, Otto is the company that displays most negative events in its sustain-ability report in this research.

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emergency exists, 21 people died. It is critical to provide evidence of which companies currently produce in the factory concerned, however, according to the supplier homep-age, Otto sourced from this factory (Clean Clothes Campaign, 2010). No information is provided on the fire incidents by Otto, however, the negative event violations of suppli-ers in the sustainability report includes incidents on health and safety regulations. This is why this event is considered as partially reported even though the company should have mention this incident in more detail in the report.

In November 2010, a German television show called “Report Mainz” together with an animal welfare organization Four Pawns discovered that there are products in the as-sortments of Baur, Ottto and Schwaab that are obtained from live plucking (Textil-wirtschaft, 2014). This event was mentioned and above that further explained, which is why it is considered as fully reported by the Otto Group. The fifth negative aspect iden-tified is the unavoidable workforce reductions that have to be implemented due to the modernization of the warehouse logistics. In total, a number of 410 employees had to be dismissed (Hamburger Abendblatt, 2009). Even though Otto mentioned the workforce reduction due to the modernization of its warehouse logistics, no exact number of em-ployees that had to be dismissed was given; therefore this event is considered as partial-ly reported.

Another event identified concerns anti-union activities of the Turkish supplier Menderes Tekstil. At the supplier factory, security breaches and anti-union activities could be de-tected by the Human Rights organization (Business & Human Rights Resource Centre, 2014). Otto mentions violations of standards by suppliers, also in the area of freedom of association, however, does not explain more on this issue. Therefore, it is considered as partially reported by the Otto Group.

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Otto. However, the EU-Commission investigated this case but approved Otto’s actions (Europäische Kommission, 2010). This event was also included in the report by Otto and is therefore considered as fully reported.

Table 4: Otto measures of transparency Source: own illustration

To conclude, out of nine negative events identified in external sources, Otto includes sevem negative events in the report themselves, 4 fully and 3 partially. This provides a mixed picture of the report since major incidents like the fire in a supplier factory or the bad working conditions at Hermes are not or only partially included. According to Otto, this report “presents an open and transparent account of the impact of the Group’s busi-ness activities on people and nature” (GRI Report page 3). The findings here show ra-ther mixed results since some major events are only partially reported by the Otto Group. However, the findings of the content analysis show that Otto’s sustainability report includes abundant information about the company and its sustainability perfor-mance. Nonetheless, the Otto Group does not include any sector supplements in its sus-tainability report, and fails to disclose ten PI completely. So, Otto does not seem to simply use the sustainability report as a marketing tool in order to improve company image since too many negative events are included in the report and too much infor-mation is provided to the reader. Rather, in some aspects, Otto is a prime example of how to incorporate sustainability throughout a large multinational company with their approach to assign each board member a core CR topic that the member personally drives forward. However, some sort of reporting-performance portrayal gap exists

Fully reported Partially reported Not reported

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tween company sustainability performance and sustainability reporting but the sustaina-bility report by Otto is the second most transparent report in this research.

6.5 Puma

Puma is one of the world’s leading sport brands that “distributes its products in more than 120 countries, employs more than 10,000 people worldwide and is headquartered in Germany” (Puma, 2014). Its products range from footwear, apparel to accessories in various categories like football, running, training, fitness, golf and motorsports.

The sport brands Nike, Adidas and Puma have been widely criticized in media amongst other for unfair labour practices in production countries over the years. This might be a reason why Puma started publishing sustainability reports since 2004 according to GRI guidelines that since 2007/2008 achieved the highest possible GRI application level of A+ (Puma, 2014 a) and even includes first-tier suppliers in the report. With these re-ports, Puma tries to differentiate themselves from its competitors on the market and thereby signal commitment towards sustainability. In case of Nike, the company fre-quently publishes sustainability reports according to GRI Guidelines since 2005 as well, however, those reports achieve application level B and are therefore not analysed. In case of Adidas, no sustainability reports in accordance with GRI guidelines are being published but social and environmental reports can be downloaded from the firm homepage (Adidas Group, 2014).

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Puma or will be included in the following report in more detail. However, since only core performance indicators are taken into consideration, Puma fails to report on nine core PI completely and partially reports on 8 core performance indicators (see 10). When looking at sector supplements, again none of the 34 supplements is included in the GRI report, nor are reasons for their omission provided.

Turning to negative events included in the report, Puma displays 4 negative events that occurred during the reporting period. The first negative event is included in the CEO statement that concerns irregularities at a joint venture partner in Greece. In the report, Puma states that these irregularities committed caused Puma to restate their financial statement for 2009 without mentioning the sum of money (Puma, 2011). Another nega-tive event concerns non-compliance of suppliers in Central America. According to the report, Puma had conducted business with suppliers who had been accused of unfair working conditions namely, paying poor wages and not allowing freedom of associa-tion. After an audit of the suppliers in question, one relationship was terminated but no further evidence was found for the accusations (Puma, 2011).

The next event also deals with the non-compliance of suppliers. Here, Puma introduced a new rating system in 2010, which required major changes in the management systems of the factories, which was simply not possible for some suppliers to implement within one-year time. This results in lower audit ratings in 2010 than the years before (Puma, 2011). The last negative event included in the report is the acquisition of a 20 per cent stake in Wilderness Holding Limited of Puma. The leading ecotourism company in southern Africa was targeted by a Survival International media campaign that ques-tioned the integrity of Wilderness Holding after accusations arose that one camp is hav-ing negative effects on local Bushmen (Puma, 2011).

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seamstresses when expressing such a desire (Kampagne für Saubere Kleidung, 2010). Another supplier that has been criticized in media is Ocean Sky that fails to meet the Code of Conduct developed by Puma in terms of safety standards and working hours. Here again no information is further provided that seamstresses work up to 60 hours a week while not having access to clear drinking water (Der Spiegel, 2011). So, this event is considered as not reported.

Table 5: Puma measures of transparency Source: own illustration

To conclude, with this report Puma tries to overcome the negative perception associated with sport brands in general. As the only major sports brand company, Puma publishes sustainability reports with the highest application level and even includes its first-tier suppliers to signal their commitment towards sustainability to its stakeholders and thereby differentiate themselves from its competitors Adidas and Nike. However, the findings from this research provide a different picture of the company report. By inten-tionally leaving out performance indicators and only reporting on 33 out of 50 core sec-tor completely, the report does not provide a transparent view of company performance. None of the 34 sector supplements are included in the sustainability report, which fur-ther lowers the level of transparency of the GRI report. When considering the negative events, only 4 from a total of 8 negative events are included in the report. Only 2 of the-se events is fully reported, namely the negative event of Wilderness Holding Limited on local bushmen and the increase in non-compliance rating due to a new rating system since no external sources were found that address this event. The other 3 events includ-ed in the sustainability report are only partially reportinclud-ed while another 3 events are not

Sustainability Reporting Guidelines: Evaluating the Transparency of Global Report- ing Initiative Reports from a Voluntary Disclo- sure and Legitimate Theory Perspective