Exposure Draft of Proposed Amendments to the SASB Standards and the IFRS S2 Industry-Based Guidance

From the outset we wish to make clear that the NFF are extremely disappointed that there has not been close and direct engagement on the development of any metrics with the agricultural sector. NFF has been delivering a world leading sustainability framework, the Australian Agriculture Sustainability Framework (AASF), supported by Commonwealth grants. The AASF has published its framework which include 19 Principles and 52 Criteria. Further, we have completed a substantive piece of work, delivered by the Commonwealth Scientific and Industrial Research Organisation (CSIRO) and known as the Data Ecosystem, which frames a detailed, robust, and defensible process to develop industry agreed metrics. The consultation process around the Report identified how complex and difficult the development of agreed and appropriate metrics is.

NFF, through the AASF, has been globally engaged on this issue, we have yet to see evidence that agreement of metrics has been successfully implemented. This makes it even more astounding that SASB believes it can (apparently unilaterally) propose measures without doing the work. It is important to note that the work of the AASF has led to alignment from a range of supply change entities (physical and financial) with the AASF Principles and Criteria. It is in the real world that these discussions should be sponsored. The isolationist approach evident here is not conducive to industry buy-in. We recommend that SASB be required to engage with industry to develop these processes, whatever their status, as a matter of priority.

The NFF’s full submission can be found here.