P03: Policy on Governance Issues – Above Green

Intent

This indicator describes the existence and scope of policies that address governance issues. Policies on governance issues assist entities with incorporating ESG criteria into their business practices.

Requirements

Select yes or no. If yes, select all applicable sub-options.

Does the entity have a policy/policies on governance issues?

Yes
- Select all governance issues included (multiple answers possible)
  - Bribery and corruption
  - Cybersecurity
  - Data protection and privacy
  - Executive compensation
  - Fiduciary duty
  - Fraud
  - Political contributions
  - Shareholder rights
  - Other: ____________
- Upload file or URL where in the evidence the relevant information can be found____
No

Validation

Evidence: Document upload or hyperlink. The evidence must sufficiently support all the items selected for this question. If a hyperlink is provided, ensure that it is not outdated and the relevant page can be accessed within two steps.

The provided evidence must cover the following elements:

Demonstrate that there is a formal policy document in place and not simply a list of general goals and/or commitments.
Specifically address each governance issue selected (e.g., a policy on issues such as cybersecurity or shareholder rights).

Other: State the other governance issue. Ensure that the other answer provided is not a duplicate of a selected option above (e.g., data confidentiality when ‘data protection and privacy is selected). It is possible to report multiple other answers.

See Appendix 2a for additional information about GRESB Validation.

Scoring

1.5 points, G

Scoring is based on the number of selected options. It is not necessary to select all options to achieve the maximum score.

Evidence: The evidence is manually validated and points are contingent on the validation decision.

Other: The 'Other' answer is manually validated and points are contingent on the validation decision.

See the Scoring Document for additional information on scoring.

Terminology

Bribery: The offering, giving, receiving or soliciting an item of value to influence the actions of an official or other person in charge of a public or legal fiduciary duty.

Corruption: Abuse of entrusted power for private gain.

Cybersecurity: The protection of internet-connected systems, including hardware, software and data, from any unauthorised use or access. Malicious attacks, in particular, can pose a significant threat to real assets.

Data protection and privacy: Customer privacy includes matters such as the protection of data; the use of information or data for their original intended purpose only, unless specifically agreed otherwise; the obligation to observe confidentiality; and the protection of information or data from misuse or theft.

Executive compensation: The financial payments and non-monetary benefits provided to high-level management in exchange for their work on behalf of an entity.

Fiduciary duty: Refers to the obligations of loyalty and care in regard to the responsibility of managing someone else’s assets. A fiduciary duty is a position of trust and examples include a duty of confidentiality, a duty of no conflict, and a duty not to profit from his position.

Fraud: Wrongful deception intended to result in financial or personal gain.

Governance issues: Governance structure and composition of the entity. This includes how the highest governance body is established and structured in support of the entity’s purpose, and how this purpose relates to economic, environmental and social dimensions.

Policy: Defines a commitment, direction or intention as formally adopted by the entity.

Political contributions: Disclosure for political contributions, such as the amounts and recipients of all monetary and non-monetary contributions made by the entity, including political contributions made through third parties.

Shareholder rights: Can include the right to share in the company's profitability, income, and assets; a proxy statement; a degree of control and influence over company management selection; preemptive rights to newly issued shares; and general meeting voting rights.

References

EPRA Best Practices Recommendations on Sustainability Reporting, 3rd version, September 2017: 7.9, Narrative on performance

GRI Sustainability Reporting Standards (2016): 102-35; 102-37; GRI 205

RobecoSAM Corporate Sustainability Assessment 2017: 3.1.7