From Transparency to Transformation: Why Corruption Standards Must Show How Change Is Achieved
Sustainability standards must exist to do more than describe reality. Their deeper purpose is to help change it. Yet too often, reporting risks becoming an exercise in documenting the status quo—identifying risks, listing policies, counting incidents—without explaining how organisations actually shift behaviour, rewire incentives, and influence outcomes across their value chains. When it comes to corruption, transparency alone is necessary but insufficient. What matters is not only what is reported, but how reporting illuminates real-world change.
This submission responds to the GRI Corruption exposure draft with that principle in mind (GSSB: Have your say, public comment period underway until 10 April 2026). The objective of the economic impact project is to reflect internationally agreed best practice and stakeholder expectations regarding organisations’ impacts on the economy and people.
This article constitutes SustainCase’s formal public comment on the GRI Corruption exposure draft, submitted as part of the Global Sustainability Standards Board (GSSB) public consultation process. It is published here to support transparency, informed debate, and practitioner engagement in the development of sustainability standards.
Why corruption is a systemic problem, not a reporting issue
Corruption is not a peripheral governance failure; it is a structural force that undermines markets, institutions, and sustainable development. Transparency International consistently shows that the majority of countries struggle with significant corruption challenges, while the World Bank estimates that over USD 1 trillion is paid in bribes annually, with several trillion more lost through distorted markets, reduced investment, and inefficiencies.
The OECD has repeatedly highlighted that corruption functions as a regressive, hidden tax. It penalises compliant businesses, rewards opacity over productivity, inflates infrastructure costs, weakens public services, and distorts competition. Over time, corruption erodes trust in institutions, weakens democratic processes, and undermines the rule of law. Where corruption thrives, environmental regulation is bypassed, labour protections are ignored, and long-term investment gives way to short-term extraction.
In this context, corruption is inseparable from climate transition, social stability, and economic resilience. Sustainability fails not because ambitions are unrealistic, but because systems are quietly undermined.
Taking the sign out of the shop window
Mark Carney has repeatedly argued—and reaffirmed in his most recent address at the World Economic Forum—that systemic risks cannot be managed through surface-level commitments or reputational signalling. Across climate, financial stability, and market integrity, his message is consistent and uncompromising: values do not change outcomes unless they are translated into incentives, embedded in systems, and enforced through accountability. Where frameworks rely on disclosure without altering decision-making structures, economic behaviour remains unchanged. In this sense, transparency that is not coupled with consequence risks becoming performative—visible, reassuring, and ultimately ineffective.
The same logic applies to corruption reporting. A policy, a training programme, or a risk assessment can act like a reassuring sign in a shop window. It signals intent. But if what happens behind the counter remains unchanged—if commercial pressure, weak controls, and misaligned incentives persist—the sign becomes meaningless.
Standards that focus primarily on identification and disclosure risk reinforcing this dynamic. They can show awareness without requiring alignment between values, systems, and economic reality.
Progress in the exposure draft — and where it stops short
The exposure draft represents a meaningful evolution from GRI 205. It broadens the definition of corruption, acknowledges systemic impacts, and explicitly brings business partners into scope. These are important steps.
However, the draft remains largely descriptive rather than transformative. As a result, the disclosures provide visibility of exposure but limited insight into how corruption risk is reduced through decision-making, incentives, and enforcement.
It requires organisations to:
- identify higher-risk functions and business partners
- describe governance roles and policies
- report incidents and actions taken
But it does not require organisations to demonstrate:
- how they use leverage to influence behaviour in the value chain
- how corruption risks translate into commercial or contractual consequences
- how responsibilities are embedded into decision-making systems, not just governance charts
- how remediation is pursued before incidents escalate to termination or legal action
As a result, an organisation can comply fully while continuing to operate within the same structures that allow corruption to persist.
Why leverage, systems, and remediation matter
In practice, corruption is rarely eliminated by awareness alone. It is reduced when:
- contracts embed clear expectations and consequences
- procurement and commercial incentives are aligned with ethical performance
- escalation pathways are defined and enforced
- remediation is time-bound, monitored, and linked to continued engagement
Without these elements, value-chain corruption risks become permanent features rather than problems to be solved.
This is not about mandating specific controls or enforcement actions. It is about making visible how power is exercised responsibly—and whether organisations are willing to change the mechanics that create risk.
Our comments for the GSSB
Comment 1 — Move from “risk identification” to use of leverage in the value chain
Issue
While the draft meaningfully expands corruption risk assessment to business partners (COR-2), it remains largely descriptive and does not require organizations to demonstrate how they use their leverage to influence or change corrupt practices in the value chain.
Why this matters
Corruption is frequently structural and sustained by commercial dependency, pricing pressure, or informal norms in supply chains. Without requiring organizations to disclose how leverage is applied (e.g. contractual conditions, remediation timelines, suspension or disengagement criteria), reporting risks normalizing persistent high-risk relationships.
Suggested improvement
- Introduce a requirement (or strengthened guidance) for organizations to disclose:
- how corruption risks identified in business partners translate into contractual, commercial, or operational consequences
- escalation mechanisms where risks remain unmitigated over time
This would better align the Standard with OECD Due Diligence expectations and real-world prevention practice.
Comment 2 — Require clearer disclosure of systems and decision rights, not only roles
Issue
Disclosure COR-1 requires naming governance bodies and roles responsible for anti-corruption, but does not require disclosure of the systems, decision rights, or escalation mechanisms through which these responsibilities are exercised.
Why this matters
Naming roles without explaining how decisions are made, enforced, and escalated limits the usefulness of disclosures for stakeholders assessing effectiveness. In practice, corruption prevention depends on embedded systems (procurement controls, approvals, audits), not only governance structures.
Suggested improvement
Strengthen COR-1 to require disclosure of:
- how anti-corruption responsibilities are operationalised across key functions
- how issues are escalated, resolved, and integrated into enterprise risk management
- This would enhance credibility and comparability without prescribing specific systems.
Comment 3 — Introduce expectations on remediation pathways, not only outcomes
Issue
Disclosure COR-3 focuses on reporting confirmed incidents and outcomes (discipline, contract termination, legal actions), but does not require disclosure of remediation pathways prior to termination or enforcement.
Why this matters
Effective anti-corruption practice often involves corrective action plans, monitored improvements, and time-bound remediation—particularly in value chains where immediate disengagement may worsen impacts.
Suggested improvement
Add guidance or requirements encouraging organizations to report:
- whether remediation plans were implemented before contract termination
- timeframes and monitoring mechanisms for corrective actions
This would better reflect how corruption risks are managed in complex value chains and avoid a binary “incident vs termination” framing.
Comment 4 — Shift training disclosures toward effectiveness, not only coverage
Issue
Disclosure COR-4 emphasises headcount and percentages trained, but does not require organizations to assess or disclose training effectiveness or behavioural outcomes.
Why this matters
High training coverage does not necessarily correlate with reduced corruption risk. Stakeholders increasingly expect insight into whether training leads to changed behaviour, improved reporting, or reduced incidents.
Suggested improvement
Encourage organizations to disclose, where feasible:
- how training effectiveness is evaluated
- whether trends in incidents or whistleblowing correlate with training efforts
This would strengthen the preventive dimension of the Standard without creating excessive reporting burden.
Comment 5 — Clarify expectations when systems or controls do not exist
Issue
Under the general GRI framework, organizations may comply by stating that certain policies, systems, or processes do not exist, without any expectation to explain implications or timelines for development.
Why this matters
For a topic as systemic and high-impact as corruption, the absence of systems is itself material information. Without further context, such disclosures risk being treated as neutral rather than as indicators of elevated risk.
Suggested improvement
Clarify, in guidance, that when key anti-corruption systems or controls do not exist, organizations should:
- explain the implications for risk exposure
- indicate whether plans or timelines for development are in place
This would enhance transparency while respecting GRI’s non-prescriptive approach.
Every grain of sand matters
It is easy to dismiss individual actions as insignificant in the face of systemic problems. But systems change through accumulation. One organisation changes how it contracts. One board insists on accountability. One value-chain relationship is rebalanced. Like grains of sand, each action appears small, yet together they shape the landscape we live in.
Standards play a crucial role in this process. If they only describe the terrain, nothing shifts. If they illuminate how pressure is applied, how systems are enforced, and how accountability travels through the value chain, they become catalysts for change.
The world at stake
A sustainable future means cleaner air and water, access to good education and healthcare, better food, secure jobs, safer working conditions, and cities where people can afford to live and enjoy life. It means protecting nature while ensuring economic opportunity—today and for future generations. Sustainability is not ideology; it is the foundation for stability, well-being, and shared prosperity.
Corruption undermines every one of these outcomes. Addressing it at the root—through systems, leverage, and accountability—is therefore not optional. It is central to whether sustainability reporting becomes a driver of transformation or a mirror reflecting the persistence of failure.
Closing reflection to the GSSB
The GRI Corruption exposure draft represents a step forward. However, for the Standard to fully meet the objectives of the economic impact project and the principles set out in the GSSB Due Process Protocol, it would benefit from more clearly demonstrating how change is achieved in practice, not only how risks are identified and disclosed. In this context, and in the interest of transparency, accountability, and stakeholder confidence in the standard-setting process, we respectfully encourage the GSSB to communicate how feedback received through the public comment process has informed the final Standard.
The GSSB public comment process is open to all stakeholders. Practitioners, assurance providers, academics, and sustainability professionals are encouraged to submit their own public comments, drawing on their experience and perspectives. You may reference this article where helpful, build on it, or offer alternative views. Broad and informed participation is essential to ensuring that sustainability standards reflect real-world practice and stakeholder expectations.
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Carney, M. (2026) Principled and pragmatic: Canada’s path, speech delivered at the 56th World Economic Forum Annual Meeting, Davos, Switzerland, 20 January. Available at: https://www.pm.gc.ca/en/news/speeches/2026/01/20/principled-and-pragmatic-canadas-path-prime-minister-carney-addresses (Accessed: 27 January 2026).
Global Reporting Initiative (2025) Topic Standards project for economic impact. Available at: https://www.globalreporting.org/standards/standards-development/topic-standards-project-for-economic-impact/(Accessed: 27 January 2026).
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Transparency International (2024) Corruption Perceptions Index 2024. Berlin: Transparency International. Available at: https://www.transparency.org/en/cpi/2024 (Accessed: 27 January 2026).
World Bank (2021) The Cost of Corruption. Washington, DC: World Bank Group. Available at: https://www.worldbank.org/en/topic/governance/brief/anti-corruption (Accessed: 27 January 2026).
United Nations Office on Drugs and Crime (UNODC) (2023) Corruption and Development. Vienna: UNODC. Available at: https://www.unodc.org/unodc/en/corruption/index.html (Accessed: 27 January 2026).
Global Reporting Initiative (2020) GSSB Due Process: Process and Terms of Reference that govern the operations of the Global Sustainability Standards Board. Available at: https://www.globalreporting.org/standards/global-sustainability-standards-board/gssb-due-process/ (Accessed: 27 January 2026).