Taking it on - developing UK sustainable development strategy together
Comments from ACCA
July 2004
ACCA is pleased to comment on the consultation paper �Taking it on, developing UK sustainable development strategy together'. ACCA recognises the importance of sustainable development both in terms of shaping what business and activities ACCA does, and how we conduct these in the future. For a professional body, our own direct impacts are small but we are not ignoring them - we have an environmental management system in place and we are currently developing our social policies. Also, as a professional body we recognise the importance of education as a tool in promoting sustainable development among our members and students, and continue to find relevant and meaningful ways of communicating this to our aspirant accountants and their national and regional representatives.
Q1. What do you think of our approach to the content and structure of a new strategy?
The introduction appears to focus on selected positive aspects, painting a picture of the UK being highly sustainable already. This is, however, misleading. The strategy should be subject to a rigorous review to identify current strengths and weaknesses, where the gaps are and in which areas we are not doing well. Learning from our failures over the last five years is important if we are to improve our contribution to sustainable development in the future. A full review and analysis of the failures of the 1999 strategy is currently missing and urgently required.
The tensions and contradictions of different policies from government need to be better explained so society and business can see by pursuing one may bring consequences to another. It could also be beneficial to explain how an individual's actions could make a contribution to making change on a local, national and/or global level.
The UK strategy must integrate all the strategies of the devolved administrations to ensure consistency and avoid excessive fragmentation.
There is a need for Government's sustainable development indicators to be capable of overlap with business sustainable development indicators, to ensure a common language and that common metrics are used.
Overall we are supportive of the seven broad aims (2.6 points 1-7). However, it is important to stress the benefits (to the environment, the economy and to society) of acting early and ensuring the strategy is successful and to explain more fully the long term implications if the strategy fails. The aims would also benefit from an explanation of how each could be achieved and what potential challenges may be. There is much talk of the government providing leadership (2.6 points 4 and 7), but so far there is little evidence of it having been provided, causing the strategy to lose momentum. This has led to a failure to produce substantial change (e.g. in sustainability reporting) which genuine leadership could bring. It is important to appreciate that transparency and reporting are an integral part of the requirement for business to take responsibility for its role in sustainable development initiatives. Without transparency � and indeed accountability - how can business progress be monitored and assessed?
It is important to recognise that a successful sustainable development strategy must achieve a change in culture. This requires a fully inclusive stakeholder consultation with all industry sectors and stakeholder groups.
Q4. What should be the guiding principles for UK decision-makers, and how can they be made widely practical and relevant both within and beyond government?
We are supportive of the 10 guiding principles, but we would like to have added a specific recognition of the importance of real transparency by organisations and the requirement to report deeper environmental and social goals and full reporting of substantive sustainability measures.
It should be explained how consensus is to be reached or how inconsistencies will work across the administrations, as currently there is little agreement across the regions with the UK principles. How can the strategy be successful or how can users be supportive if there is disagreement within government itself?
Other principles should be considered including: biodiversity, equity, global impacts and, as included in the Scottish Executive's principles, conserving resources.
Q5. Are there any social, economic or environmental limits that must be protected in all circumstances?
How do you define a limit?
There has already been a wealth of research undertaken regarding human impact on environmental capacities, and it is generally accepted that we are living beyond our limits (for example, resource use, climate change, waste production, pollution, biodiversity loss, water quality).
Regarding social aspects, a commitment to human rights as articulated in the UN Declaration of Human Rights should be protected in all circumstances.
Q6. Are the four priority areas identified above the right ones for the UK as a whole to focus on over the next few years?
It would be helpful to specify when these priorities will be reviewed, so we are aware of the timescales involved and thus what the priorities should be within that timeframe. Do these priorities apply to all: government, domestic and business use? If not, there should be explicit mention of the responsibility of business and the need for greater accountability of their impacts on society and the environment.
The priority �environment and social justice' is a little broad � what does this actually include?
Additional priority areas that should be considered are waste production and biodiversity. A commitment to human rights should also be considered as a priority area, and a further priority area should be the UK 's overseas impact (which arises through exporting pollution, overseas investment, outsourcing of labour and supply chain impacts which collectively are significant).
Q7. What issues do you think are important or better dealt with only within the separate UK Government and separate administrations?
A distinction should be made between measuring sustainability impacts and taking action to alter them. It is therefore important to monitor local performance nationally, irrespective of where action is best taken. Consistency in approach and indicator selection is crucial across all administrations to enable an accurate measurement of national progress. Joined up thinking and collaboration is required from all parties.
Q10. What opportunities are there for making sure that considering the impacts of climate change are an essential part of policy and decision-making as part of the drive for sustainable development?
For others to consider the impacts of climate change as an essential part of policy, the UK Government needs to lead by example and integrate climate change issues throughout all its decision-making processes and policies.
Accountability and transparency would also serve as a key driver: organisations should be required to disclose GHG emissions data and their climate change policy, together with trend data to show performance over time and strategies in place to reduce their impacts. In addition, organisations should be required to disclose their public policy issues in this area. This could be introduced as a mandatory requirement for specific sectors and businesses (in the first instance), including national and local government.
The strategy also needs to tackle the key challenges in this area which include meeting the growing need for energy (on both a global and national basis), measuring the contribution (effectiveness) and identifying potential limitations of renewable energy, and explore how to engage the developing world in order to address their needs.
Q21. How can communication and raising awareness support government and others' efforts most effectively?
The sustainability implications of alternative policy options should be explored whenever a policy debate is initiated.
Sustainability should be much further enhanced within educational curricula at all levels from primary to secondary education to appropriate parts of tertiary level studies (e.g. business schools). The UK Government has already begun to identify which MBA courses have a sustainability aspect to the syllabus via its newly launched CSR Academy : this should be expanded to include all types of courses. It should be noted there is also a considerable amount of research on which universities do not educate for sustainable development, and we encourage the government to take this issue forward with each of them.
Government could also do more to promote business ethics and to raise awareness of ethics through training and education at all levels.
Government should be seen to promote, or campaign for, more sustainable products for example: taxing waste, calling for greater recycling efforts, promoting and rewarding best practice. Any form of communication must be engaging, two-way and inclusive.
Q22. What are the top international and EU priorities for sustainable development that should be dealt with in the new sustainable development strategy?
The UK Government should actively support the development of coherent international strategies, based on systematic measurement as well as awareness raising. The UK 's national performance should enable EU and international monitoring of sustainability performance globally.
Regarding priorities, climate change (and associated energy use and reliance on fossil fuels) should be the top priority for sustainable development. Poverty, human rights, biodiversity, resource use and waste production are other priority areas that should be considered.
Q23. How can we in the UK , at all levels, do more to help other countries achieve sustainable development and to promote and deliver sustainable development internationally or in the EU.
We can only expect others to achieve sustainable development and listen to us if we set a good example here in the UK first. We must therefore first implement a successful and effective sustainable development strategy ourselves before disseminating this and other advice to others.
Q26. What more do we in Government need to do to improve our own leadership in sustainable development? How would you like to see reporting improved?
Greater co-ordination across government and consistency of reported data is required. Reporting should become more strategic and less simplistic. National and local government should report on its own direct impacts, for example through reporting in accordance with Global Reporting Initiative (GRI) guidelines. Report users should be able to compare between government offices and be able to aggregate the data to calculate the overall impact and performance of government.
National and local government procurement policies should require that sustainability considerations be included as key constraints to purchasing decisions, and national government procurement should require of tendering organisations that they include their organisation's sustainability report as a necessary part of the tender.
The UK national and international CSR strategies should not only be consistent with, but also seen as itself the articulation of the national sustainability strategy for business.
Q36. What more needs to be done to improve the business contribution to delivering sustainable development?
This Government has spent several years threatening compulsory social and environmental reporting which has come to nothing. The Blair 2001 challenge to the FTSE 350 to report also failed, mainly because there was neither follow-up nor any exposure of those companies which failed to report. Some feel the Government has again missed the chance through the company law review by ending up with a minor requirement in the new OFR.
Complete and credible transparency and accountability will serve as a key driver to improve the business contribution to delivering sustainable development, so the answer is straight-forward: the UK Government needs to ensure that business reports regularly and effectively against its sustainability impacts and risks, which needs to be far more systematic than that is currently envisaged in the proposed OFR regulations.
As stated in Q21, issues of sustainable development should be made a pivotal part of any business qualification.
Q37. What actions should we take to support, enable or require a higher level of business contribution?
See answer to Q36.
Q38. What are the strengths and weaknesses of the current sustainable development indicators, and how they are used?
The current indicators do not appear to be connected to other policy decisions and may be readily sacrificed to short-term ends. The sustainable development indicators should be capable of regional and local disaggregation and international aggregation at the European and global levels.
The economic dimension of sustainability is not well captured by the current indicator measuring growth. Not all growth is sustainable; new economic indicators should be developed which do not include inherently unsustainable activity just because it contributes to GDP. In addition extra indicators need to be developed to capture aspects of the structure of local economies which promote sustainability.
The UK sustainability performance should be formally integrated into the national accounts.
Q40. Who are the audiences for indicators and how could we better meet their needs?
All levels of government, from international to local are one of the principal audiences of the indicators as they must adjust policy directed at the behaviour of others, as well as their own behaviour, to approach sustainability. On this perspective, the indicators must be integrated into the policy development process.
However, as the indicators are broad other stakeholders may find specific indicators of interest and use to them.
Q42. Should important high-level sustainable development indicators focus on monitoring (i) general progress towards final outcomes (ii) specific delivery actions and targets or (iii) both?
It is important that both general progress as well as specific performance is monitored, otherwise neither can be assessed.