The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How Challenger promotes business integrity

Challenger is Australia’s largest provider of annuities, providing reliable, guaranteed income payments to thousands of Australian retirees. Challenger recognises that its ability to continue to deliver value for its stakeholders relies on trust and confidence in its business. Accordingly, Challenger has set and maintains high standards of conduct  Tweet This! and actively engages in industry-wide commitments.

This case study is based on the 2020 Sustainability Report by Challenger published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Challenger’s values are integral to its culture and linked to everything Challenger does. They represent what makes Challenger’s culture special and set out the behaviours Challenger needs to meet community expectations and make sure it can deliver on its vision and strategy. In order to promote business integrity Challenger took action to:

  • implement a Code of Conduct
  • apply a Political Donations policy
  • implement a Privacy policy
  • develop a Whistleblower policy

What are the material issues the company has identified?

In its 2020 Sustainability Report Challenger identified a range of material issues, such as long-term risk management, better customer outcomes, changing operating environment, public policy settings, economic uncertainty. Among these, promoting business integrity stands out as a key material issue for Challenger.

Stakeholder engagement in accordance with the GRI Standards             

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Challenger engages with:

To identify and prioritise material topics Challenger engaged with its stakeholders through the following channels:

Stakeholder Group                Method of engagement
Customers ·       Survey

·       Call centre

·       Website and social media

·       Presentations

Shareholders ·       Regular financial reporting

·       Investor Days

·       Management meetings with investors and prospective investors

·       Chair engagement with significant investors

Employees ·       Intranet and Yammer

·       Employee briefings

·       Surveys

·       Senior leadership forums

·       ESG workshops

·       Ongoing team meetings

Government & regulators ·       Policy analysis

·       Government and industry submissions

·       Industry forums and conferences

·       Ongoing meetings



·       Strategic partnership

·       Volunteering

·       Workplace giving & matching

·       Fundraising initiatives

·       Shared research activities

What actions were taken by Challenger to promote business integrity?

In its 2020 Sustainability Report Challenger reports that it took the following actions for promoting business integrity:

  • Implementing a Code of Conduct
  • In February 2020 Challenger refreshed and updated its Code of Conduct. The Code sets out expectations for how Challenger acts, solves problems and makes fair and balanced decisions. It brings together Challenger’s corporate values and its group policies and statements, outlining what is expected of leaders, how consequences are managed, and where employees can go to speak up. Challenger’s Code of Conduct sits across all areas of its business and applies to everyone, irrespective of their role, seniority or any other factor, and all Challenger employees have a shared Delivering on the UN SDGs responsibility to apply it consistently.
  • Applying a Political Donations policy
  • Challenger has taken the approach of not making political donations and understands the importance of following best practice approaches and remaining flexible to changing community expectations. At the same time, Challenger engages actively with politicians and other government representatives to contribute to effective public policy outcomes in a way that meets the expectations of its stakeholders and supports its customers and business.
  • Implementing a Privacy policy
  • Challenger follows a ‘privacy-by-design’ approach, where privacy drives decision-making processes. This approach applies to every stakeholder and is used throughout Challenger’s Challenger’s Privacy policy sets out its approach for making sure it manages its customers’ information in a way that meets existing privacy regulations and customers’ expectations. Challenger has had no significant privacy complaints or breaches during the 2020 financial year and was not required to make any data breach reports to the Office of the Australian Information Commissioner under Australia’s Notifiable Data Breaches scheme during the year.
  • Developing a Whistleblower policy
  • Challenger is committed to demonstrating transparency and enhancing stakeholder trust. Through its whistleblower provisions, employees, contractors, former employees, suppliers, service providers and relatives are encouraged to speak up. Challenger’s Whistleblower policy outlines the process for raising concerns and the protections and support available to whistleblowers. Challenger provides an independent whistleblower service so users can easily raise concerns through multiple channels and be assured of their anonymity if they desire.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 415-1 Political contributions

2) Disclosure 418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data

3) Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area


Disclosure 415-1 Political contributions corresponds to:

Disclosure 418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data corresponds to:

Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area corresponds to:


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

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By registering for the next 2-day FBRH GRI Standards Certified, IEMA & CIM recognised course you will be taking the first step in gaining the many benefits of sustainability reporting.

Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



1) This case study is based on published information by Challenger, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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