Speaking out on 14001

Lucy Candlin and Ben Vivian believe that complying with a revised clause in 14001 on communication could test practitioners

Some of the changes to ISO 14001 appear large and potentially scary, while others are less extensive and, on the surface, not so challenging. The revised clause on communication fits into the second category, but could turn out to be one of the most challenging for environment professionals and organisations.

The key changes in revised clause 7.4 (see panel 3 below for a comparison) are the addition of the word "reliable" and an explicit requirement to link communications back to performance output information of the environment management system (EMS) as well as the introduction of a planned and controlled process.

Getting feedback

At the IEMA EMS forum in November 2014, we asked practitioners their thoughts on the implications of the changed language relating to communication in the revised 14001 standard. The first question was: what communications does an organisation issue that might be relevant?

The challenge was to refocus minds from "environmental communications" to "communications with environmental content". This was potentially far broader than many of the participants expected, and could include internal, external, formal, informal, written, verbal, local, global and corporate communications. Panel 1 below summarises some of the audience's responses.

In essence the revised clause requires the organisation to think about any environmental information released in any form outside the company as well as what it releases internally. Alongside more formalised communications, which transmit actual messages, organisations need to consider implied messages that are given by actions and behaviours, and messages given out by staff, contractors or others working with the organisation.

The next question put to the audience was: what is environmental information? The responses are summarised in the panel 2 below and readers can probably easily add to that list from their own experiences. A key point to remember is that information may be both quantitative and qualitative; it might be based on number data from the EMS or research, analysis, interpretation and judgment.

Our final question was: what does "reliable" mean? The answers are summarised in panel 4 below. A common response was that reliable information had to be audited. We checked this interpretation with Martin Baxter, chief policy advisor at IEMA and head of the UK delegation on the working group revising 14001. His response was clear: "One thing to emphasise is that the standard is not requiring that all environmental information is audited, but that it is controlled."

We analysed the audience responses and looked at recognised definitions and commonly accepted principles of accounting for financial and non-financial data. To be reliable, information must be "a faithful representation of reality" and be "true, fair and balanced". If this is the case, people who base their decisions on the information should have a reasonable expectation of the outcomes.

The principles of communication

ISO 14033 lists some useful principles for quantitative environmental information. These can also be applied to qualitative information. The chart (panel 5, below) illustrates how information can be structured to show how each principle supports others in underpinning reliability - or credibility, as 14033 describes it.

Other principles also apply and organisations should consider using them all when developing their communications. Examples of these include making sure information is:

• relevant for the needs of users;
• produced in a timely fashion; and
• explained in an appropriate (neutral) way - that is, using language appropriate for the audience and the subject matter without bias or spin.

Reliability is one of the principles set out in the G4 sustainability reporting guidelines from the Global Reporting Initiative. It is defined in G4 as: "The organisation should gather, record, compile, analyse and disclose information and processes used in the preparation of a report in a way that they can be subject to examination and that establishes the quality and materiality of the information."

The guidelines add: "Stakeholders should have confidence that a report can be checked to establish the veracity of its contents and the extent to which it has appropriately applied reporting principles."

In the GRI-G4 context, reliable information is that which can be checked, but the broader principles imply more than this, especially in the context of interpretation, bias and relevance. The accounting system(s) through which environmental information is controlled need to take account of the range of principles underpinning reliability.

Consideration should also be given to the principle of materiality - the importance and significance of an issue - when developing communications. Environmental reporting guidance has encouraged professionals to consider this to mean its relevance or significance for readers. This is similar to the way in which 14001 uses significant to evaluate environmental aspects and impacts to identify what is important for the organisation to control and respond to.

Materiality has another meaning, however, and one that is more commonly used in business management and from which it is essential to distinguish when planning communications. Most company boards will have a materiality threshold to determine risk levels and issues for them to consider; this threshold is usually - but not always - a financial value.

In relation to environmental communications, it is important to recognise that for many organisations the environmental issues that practitioners consider important may never reach management's financial materiality threshold or cannot be expressed in financial terms even though they may be significant to an organisation's performance or reputation. Clarity is therefore required in communicating with management about this and in defining elements of the planned communications process.

Clause 7.4.1

The EMS forum considered the questions an organisation should ask itself in order to plan a communications process consistent with the intent of clause 7.4.1 - in particular, what an information control process should look like.

Panel 6 below summarises these questions as a checklist for organisations moving to the revised standard, while panel 7 outlines some of the elements to be considered in developing an information control process.

There are many things for environment professionals to think about to ensure that information is reliable when communicated internally or externally. It means that meeting this element of 14001: 2015 needs to be considered early in a transition process. This is likely to involve many people and parts of the organisation that have not been in close contact previously with the EMS.

There are several other ISO standards that could provide information to support the evolution of a communications control process from the perspective of the revised 14001. These include 14031, 14033, 14063, and 14064-3 as well as the emerging ISO-FDIS 50015. Both 14064-3 and 50015 relate to monitoring and verification of greenhouse-gas emissions and energy information, subject areas that require high levels of control and assurance over the information that is disclosed. As such, they provide a useful source of good practice information that can be applied flexibly to other areas of environmental communication.

Areas of practical interpretation will emerge as certification of the revised standard proceeds. Notwithstanding all the requirements of various standards, the ownership of the diverse nature of communications, which are likely to contain environmental information, may make control complex. Environmental professionals are likely to be in the position of "owning" some significant information in communications but have little ownership over how it is conveyed.

One area that may become contentious is the reliability of analysis or interpretation of quantitative data. Although the information may be reliable, the interpretation placed on it by the company might not always present a balanced or objective position. This is when "spin" and "greenwash" are likely to become meaningful risks. Better technical competence in communications teams is perhaps required to make statements based on environmental information.

1. Types of environmental information

• Key environmental performance indicators selected for the EMS.
• Objectives and targets selected for the EMS and progress towards them.
• Results of performance monitoring and reviews, compliance evaluations, significant aspects and impacts evaluations.
• Energy and other environmental statistics - organisational performance and product/ service claims, for example.
• Climate change (and associated issues) risk evaluation.
• Climate change adaption proposals/responses.
• Supply chain impacts and performance.
• Biodiversity and ecology impact and performance.
• Permit condition compliance and monitoring information.
• Business risks resulting from changing external environmental conditions.

2. Types of communication that may contain environment content

• Annual company report and financial accounts.
• Investor briefings/investment statements.
• Forecasts/backcasts/scenario planning/strategy planning.
• Mergers and acquisitions/due diligence/audit and review reports.
• Policies/governance/values statements.
• Regulatory reporting - for example, greenhouse-gas reporting and compliance notifications under the energy savings opportunity scheme.
• Briefings/reports to management/board/staff and associated meeting minutes.
• Company brochures, leaflets and other public relations/marketing material, including press releases/news and media articles.
• Internet/intranet (webpages)/Twitter/Facebook/other social media.
• Presentations/conference speeches.
• Employee and subcontractor recruitment/induction/awareness/training information.
• Product/services brochures/manuals/leaflets/performance claims.
• Sales claims/proposals/tender submissions/contract specifications and associated documents.
• Sponsorship/advertising campaigns.
• Community/stakeholder engagement and reporting.
• Performance review/benchmarking.
• Regulatory (environmental) permit monitoring reports.
• Sustainability/CSR/environment reports.
• Declarations/ratings/benchmark reporting - for example, DJSI, CPD, FTSE4Good.

3. 14001 clauses

4. Contributors to reliability

• Transparent/open/clear as to source, definitions, meaning.
• Being able to back up statements with evidence/testimony/references; verifiable.
• Neutral - no "greenwash", bias or spin.
• Validated/audited (internally or by third party).
• Documented protocol/methodology/standards for accounting for/determining data and information across the data flow: generation - manipulation - interpretation.
• Signed off and authorised for release by a competent accountable person.
• Based on recognised monitoring/accounting principles.

5. Relationship between accounting principles

6. The planning process and constraints

Initial questions to consider

• What existing communications are made, by whom, for what purpose, and through which channels?
• Are there feedback loops to pick up issues with disclosed information?
• What are the current risks of inappropriate use of information? Is there consistency between different types of information released? Do you know how third parties use disclosed information?
• Who is authorised to sign off communications with environmental content? Are they qualified to do so? Do they know enough to validate data and interpretations released for it to be reliable?
• What control systems are in place? Do they conform to good practice for reliable data? Are there processes of validation/verification of data/information before release?
• What response protocols are in place to ensure appropriate environmental information is communicated by management/others in response to questions?

Potential constraints

• Stakeholder expectations.
• Timeliness of data - is it out of date by the time it is released?
• Organisational context and culture.
• Resources - the people and capabilities available for good quality information and communications disclosure.
• Commitment of management and other key departments, such as marketing/communications; procurement/contracting; and internal control/risk.
• Questions of confidentiality or legal obligations to disclose.

7. The information control process

• A communications matrix to identify channels and types of communication and to evaluate risk: for example, intended purpose (historical, predictive, horizon scanning); types of data needed, such as qualitative and quantitative; intended audiences; levels of accuracy/detail required by users of information; the need for independent assurance over some datasets; where/how spin/bias might be introduced; what use information might be put to by internal and third parties.
• A communications policy stating what information is controlled and who is authorised to release it. This must integrate or link to any brand and branding guidelines that an organisation has.
• Subject matter experts to be involved in sign off/release authorisations.
• Define the core primary dataset to be collected and validated, including aligning the context of collection/generation with that of reporting/disclosure.
• Documented accounting protocols to enable validation and to facilitate evidence.
• Identify existing systems to collect and control data/information flow and who "owns" them.
• Approved "library" of validated environmental information that can be used as a source for communications - for example, an IT database or other reference point to eliminate multiple routes to data, which could cause inconsistency.
• Awareness training for personnel with communications responsibilities/opportunities.
• A process for feedback - particularly when the reliability of information is challenged.