1.1 Part A: Respondent information

Please remember that all of this is optional.

The purpose of the questionnaire is to collect all your views in the comments to the questions, and we kindly ask you to provide comments strictly related to the questions.

Guidance for respondents

Comments are requested from November 1, 2024 until December 31, 2024.

For the purposes of this consultation, extensions of time are not possible and only responses provided within the specified timeframe will be considered.

This form is intended to provide Stakeholders with an opportunity to provide comments on the Get It Fair 2.0 program.

Respondents should first download the program documents available on the website at the Get It Fair page …

In the first part, the form asks for some information about the respondent.

The use of the form will facilitate the automatic aggregation of responses.

It is possible to answer all questions or only a selection of them.

To facilitate our consideration of your comments we kindly ask you to:

  • For each question first provide a synthetic answer using the drop-down menu under each question.
  • Complete the response if necessary with more elaborate comments. In providing comments we kindly ask you to:
    • Answer the questions directly.
    • Provide the rationale for your answers. If you disagree or partially agree with the questions, please specify the reasons for your position and indicate suggestions for changes to be made to the program documents.
    • Identify the specific aspects of the GIF Framework to which your answers relate, for example, by referring to the title of an area of the GIF Framework or to the specific paragraph in the Regulation.
    • Avoid inserting tables or text boxes in your responses because this makes the automatic aggregation of responses more difficult.
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1.2 Part B: Overall issues on the programme

1.2.1 Demand for corporate sustainability information

Do you agree that there is a growing demand from various stakeholders—including customers, banks, insurance companies, investors, and regulatory authorities—for accurate, reliable, and credible corporate sustainability information? Additionally, do you think companies should strive to minimize time and costs when preparing and disclosing such information to provide stakeholders with consistent, comparable insights on sustainability and responsibility? If not, please provide your comments or suggestions.

1.2.2 Forward looking sustainability information

Do you agree that the corporate sustainability information requested by different Stakeholders (customers, banks, insurance companies, investors) as well as the regulatory authorities should focus on 'forward-looking' risks to better support decision-making when establishing business relationships with an organization? "If not, please provide your comments or suggestions.

1.2.3 Public Interest suitability

Do you agree that the Get It Fair programme, considering the scopes (ESG Rating and sustainability reporting assurance) on voluntary basis, effectively addresses public interest and stakeholders' needs for accurate, reliable, and credible information on an organization’s sustainability and related risks? If not specify your comments, if any.

(See Regulation paragraph 1.2)

1.2.4 Applicability

Do you agree that the Get It Fair Programme can be applied to organizations irrespective of sector, size, localization, and maturity, to provide stakeholders with accurate, reliable and credible sustainability information? If not specify your comments, if any.

(See Regulation paragraph 1.2)

1.2.5 Exclusions

Do you agree that the list of exclusions in the Get It Fair programme is appropriate for a programme focused on ethics and sustainability? Is it clear that the sustainability reporting assurance excludes organizations subjects to legal obligations relating to the mandatory sustainability reporting assurance unless the applicable laws authorizes accredited bodies in accordance with ISO/IEC standard to perform this activity? If not specify your comments, if any.

(See Regulation paragraphs 1.2.1 and 1.2.2)

1.3 Part C: Programme Governance

1.3.1 Programme Governance

The organizational governance structure of the Programme is based on clear separation of roles of all players: Scheme Owner, Accreditation Body, Programme Operator and Validation Bodies. Do you agree that the Governance system provides the interested parties with confidence that there are no conflicts of interest among all players? If not specify your comments, if any.

(See Programme Governance)

1.3.2 Accreditation value

The Get It Fair Program has received a positive evaluation for accreditation purposes based on the ISO/IEC 17029 standard by a national accreditation body (Accredia), a signatory of a Multilateral Mutual Recognition Agreement (MLA). This body is also responsible for accrediting assessment bodies according to the ISO/IEC 17029 standard and the Get It Fair Program. Do you agree that accrediting the program and validation bodies according to international standards is adequate to provide stakeholders with the expected level of credibility? Do you agree that the accrediting the Programme and the validation bodies according to international standards is adequate to provide Stakeholders with expected credibility? If not specify your comments, in any.

1.3.3 Relevant Ethical Requirements

Do you agree that the Get It Fair program regulation adequately addresses the independence and ethics requirements of bodies and evaluators through the adoption of the IESBA Code of Ethics, an international standard recognized by more than 130 jurisdictions worldwide and also applied to accounting firms and statutory auditors? If not specify your comments, in any.

(See Regulation paragraph 1.4)

1.3.4 Competence requirements

The Program requires that conformity assessment by a CAB be carried out only by professionals who hold credentials certified by an independent third-party body accredited against ISO/IEC 17024 and the GIF AP Credentialing system personnel certification program, which is itself accredited. Do you agree that this approach ensures a homogeneous level of competence and, therefore, a higher level of reliability of the evaluation process? If not specify your comments, in any.

(See Regulation paragraph 1.4)

1.4 Part D: GIF Framework

1.4.1 Sustainability matters coverage

The GIF criteria’s structure is composed of 5 interdependent criteria: one criterion focused on the Governance and management system, and four criteria focused on specific sustainability matters and related risks (social, health and safety, environment, business ethics). Do you agree that the GIF Framework covers all the sustainability matters addressed by international guidelines (e.g. OECD), regulations (e.g. EU Directives) and voluntary standards (e.g. ISO 26000)? If not specify your comments, in any.

(See GIF Framework paragraph The criteria)

1.4.2 GIF Framework structure

The GIF Framework is organized into three logical levels: : Criteria (e.g.: Social), Areas (e.g.: Human Rights) and Topics (e.g., Forced Labor) where topics relate to specific aspects of sustainability and Areas and Criteria are aggregation of topics at different level. Do you agree that this structure provides sufficient detail for assessing both governance and management systems, as well as sustainability aspects and risks?

(See GIF Framework Section Criteria)

1.4.3 Topics’ structure

All Topics of the GIF Framework share the same structure containing: the purpose and metric of the Topic, a general description, the list of evaluation elements with explicit references to the GRI and ESRS reporting standards, the key indicators (both leading and lagging), and references to other areas of the GIF Framework. Do you agree that this structure ensures the clarity of the contents of each Topic for stakeholders (organizations, assessors and external parties)? If not, provide comments, if any.

(See GIF Framework Section Structure of the Topics)

1.4.4 Assessment points – Criterion Governance and management syteme

The list of evaluation elements for each Topic of the criterion “Governance and management system” is based on the following assumption: "a process can be defined and implemented with different approaches". For this reason, the list of evaluation elements is indicative rather than exhaustive. The effectiveness of the evaluation elements depends on the processes and the external context of the organization. Do you agree that it is the responsibility of the organization and the assessors to determine the effectiveness of an approach or result of the internal processes and along the value chain by relating the evaluation elements to the external context of the organization? If not, please specify your comments, if any.

(See GIF Framework Section Structure of the Topics)

1.4.5 Assessment points – Criteria Social, Health & Safety, Environmental and business ethics

Each Topic of the Social, Health and Safety, Environmental and Business Ethics criteria contains a non-exhaustive list of assessment elements categorized according to the phases of the risk management process (identification, assessment, mitigation plans and remediation plans) and associated with probability and/or consequence. This approach aims to evaluate whether a given risk is managed appropriately within an integrated sustainability management system based on its relevance to the organization. Do you agree that this logical approach of the assessment elements is adequate to guide the assessment of the organization’s level of exposure to risk (stemming from both its activities and those of actors along the value chain) and the resulting impacts on the organization? If not, please specify your comments, if any.

(See GIF Framework Section Structure of the Topics)

1.5 Part E: ESG Rating calculation

1.5.1 GIF scoring system approach

The Get It Fair program's scoring system aims to transform professional judgement based on a set of qualitative elements into a score ranging from 0 to 100. Do you agree that the scoring approach facilitates the comparison of the evaluation results for the same organization over time as well as the comparison with other organizations? If not, specify your comments, if any.

(See GIF Framework paragraph 6.1)

1.5.2 Approach to governance and management system Topics scoring

The evaluation of the "Governance and management system" criterion involves assigning a score from 0 to 100 based on a set of evaluation elements organized following the PCDA (Plan Do Check Act) logic. Do you agree that this metric allows to determine the level of effectiveness of approaches to the fundamental processes within the governance and management system? If not specify your comments, if any.

(See GIF Framework paragraph 6.2.1)

1.5.3 Approach to scoring related to specific sustainability matters and risks

The level of exposure to risks in the Topic of the criteria "Social", "Health and Safety", "Environment" and "Business Ethics" is estimated by assigning a score from 0 to 100 based on a set of assessment elements organized according to the risk assessment logic (Identification, evaluation, mitigation plans and remediation plans) and with an approach that estimates the probability and consequences of a risk. Do you agree that this method is suitable for estimating the level of exposure to risks according to a forward-looking perspective? If not, please specify your comments and suggestions, if any.

(See GIF Framework paragraph 6.2.2)

1.5.4 Minimum evaluation threshold

To successfully pass the Due Diligence process, the Get It Fair Program requires meeting three minimum score thresholds: 1) a score of at least 40/100 on all core Topic 2) a score of at least 40/100 on the Governance and Management System criterion (average of the scores assigned to each Topic within the criterion) 3) at least 40/100 calculated as average of the scores assigned to every Topic of the GIF Framework. Do you agree that the system of minimum thresholds is effective in providing stakeholders with a balanced judgment on the overall effectiveness of the governance and management system and the level of exposure to risks across the four specific criteria of the GIF Framework? If not, please specify your comments and suggestions, if any.

(See GIF Framework paragraph 6.2.3)

1.6 Part G: Sustainability reporting assurance

1.6.1 Sustainability reporting assurane scope

Is the purpose of Get It Fair’s Voluntary Sustainability Reporting Assurance clear? If not, please specify your comments and suggestions, if any.

(See Regulation Paragraph 1.1.2)

1.6.2 Differentiation of Limited Assurance and Reasonable Assurance

By adopting the ISSA 5000 standard, does the Get It Fair program provide a useful baseline for performing the sustainability report compliance assessment with both limited and reasonable assurance and does it differentiate, appropriately, the work to be done between the two assurance levels? If not, please specify your comments and suggestions, if any.

(See Regulation Paragraph 1.6.3 and section 4)

1.6.3 Preliminary Knowledge of the Engagement circumstances

Does the Get It Fair program provide sufficient clarity regarding the VVB (Verification/Validation Body) responsibility to acquire preliminary knowledge about the sustainability information that will be assessed and the scope of the proposed assurance engagement? If not, please specify your comments and suggestions, if any.

(See Regulation Section 4.2)

1.6.4 Pre-engagement – Staekholder engagement and material topics

In the pre-engagement phase, the Get It Fair program requires the CAB (Conformity Assessment Body) to entrust an assessor with the task of verifying the stakeholder engagement process and the way in which material issues have been identified in order to determine their reliability. Do you agree that this activity is essential to properly target the assessment of the ESG rating and sustainability report? If not, please specify your comments and suggestions, if any.

(See Regulation Paragraph 4.2.1)

1.7 Part H: Assessment process

1.7.1 Pre-engagement – Information provided by the organization

During the pre-engagement phase (ISO/IEC 17029 Clause 2), the CAB (Conformity Assessment Body) must collect the following information from the organization: self-assessment questionnaire, sustainability report or a duly-filled 311 information form, the Stakeholder engagement approach, and list of material topics. These documents are used as input for preparing the assessment plan. Do you agree that this information is sufficient? If not, please specify your comments and suggestions, if any.

(See Regulation Section 4.2)

1.7.2 Pre-engagement – Stakeholder engagement and material topic

During the Pre-engagement (ISO/IEC 17029 – Clause 9.2), the Program requires the Validation Body to collect detailed information on the Stakeholder engagement process and on the consistency and completeness of the material topics identified by the organization with respect to its external context, its internal processes and its value chain. Do you agree that the results of this activity are sufficient to prepare the assessment plan? If not, please specify your comments and suggestions, if any.

(See Regulation Section 4.2)

1.7.3 Pre-engagement – Risk Assessment

During the Pre-engagement (ISO/IEC 17029 – Clause 9.2), the Program requires the Validation Body to carry out an assessment of risks that may compromise the accuracy and reliability of sustainability information, both in the form of an ESG rating validation and in the form of a statement of conformity of the sustainability report verification. Do you agree that this activity is suitable to decide whether to accept or reject the assignment? If not, please specify your comments and suggestions, if any.

(See Regulation paragraph 4.2.5)

1.7.4 Assessment Planning

In accordance with ISO/IEC 17029, the Programme requires an AVB to prepare an assessment plan to determine the activities to be carried out at the site, the skills required for carrying them out, the timing, the risks of errors and the evidence to be collected. The Programme also defines an indicative distribution of the assessment time to verify specific sustainability aspects and risks and provides for the possibility of variations depending on the relevance of the material topics. Do you agree that in this way the plan allows to evaluate, with due attention and care, every relevant aspect of sustainability? If not, please specify your comments and suggestions, if any.

(See Regulation paragraph 4.4.3)

1.7.5 Execution - Audit at site

The Due Diligence process of the Get It Fair program requires that part of the assessment activity be conducted at the organization's premises to verify the truthfulness of historical data and information, and the reasonableness of assumptions, limitations and methods used. This approach aims to more accurately estimate the level of exposure to actual or potential risks. Do you agree that the on-site audit is essential to provide more accurate and verified sustainability information? If not, please specify your comments and suggestions, if any

(See Regulation paragraph 4.5.2)

1.7.6 Execution – Forward looking information

In accordance with ISO/IEC 17029 (9.5.4), during the execution of the site visit, the Assessment Team must collect evidence on: 1) the truthfulness of data and information declared by the company 2) observe (also through interviews) the effective implementation of the processes’ approaches and 3) verify the consistency and feasibility of objectives and plans for improvement and mitigation of risks. Do you agree that this approach allows to collect evidence on confidential information while ensuring greater accuracy and reliability of the information compared to self-assessment or other assessments based on publicly available or unverifiable information? If not, please specify your comments and suggestions, if any.

(See Regulation section 4.5)

1.7.7 Execution - Interviews

Assessors must devote a significant part of the assessment time to conducting interviews with a representative sample of the organization's personnel at different levels (Top Management, white-collar workers, blue-collar workers) and from different functions, with the aim of detecting any contradictions between the statements and consolidating the judgment on the real effectiveness of the approaches and the level of exposure to risks. Do you agree that staff interviews are a fundamental element to verify sustainability information more accurately and reliably? If not, please specify your comments and suggestions, if any.

(See Regulation paragraph 4.5.2)

1.7.8 Esecuzione - i-Audit app

The Get It Fair Program requires that Due Diligence be conducted with the support of an app made available by the Program to the Validation Bodies (i.e. Assessors) which can be accessed on mobile devices (phone, tablet, etc.) anywhere and at any time. The app enables users to record evidence, take photographs, and quickly prepare the final report to be submitted to the organization. Do you agree that the support of an app facilitates the review process and leads to greater consistency in the assessment reports? If not, please specify your comments and suggestions, if any.

(See Regulation paragraph 4.5.2)

1.7.9 Reporting requirements

The Get It Fair program specifies the information that must be included in the final assessment report for both ESG rating and sustainability reporting. Companies that complete the Get It Fair Due Diligence process receive a final assessment report with all the evidence and areas for improvement (strictly confidential) as well as a report summary that can be publicly disclosed. Do you agree that the information provided is complete and meet the organization’s needs? If not, please specify your comments and suggestions, if any.

(See Regulation paragraph 4.6.1 e 4.6.2)

1.7.10 Review

ISO/IEC 17029 requires the final report to be reviewed by persons who were not involved in performing the validation/verification. In the Get It Fair program, the review serves three fundamental purposes: 1) to verify the consistency between the evidence collected and the score assigned; 2) verify the consistency between the evidence collected and the conclusions of the report; 3) verify the consistency between the conclusions of the report and the score assigned. If there is any doubt, the reviewer must request clarification from the Team Leader. Do you agree that the Review of the Assessment Team’s activity reduces the risk of inaccuracies and inconsistencies in the final report before reaching a conclusion? If not, please specify your comments and suggestions, if any.

(See Regolamento paragraph 4.7)

1.7.11 Decision

According to ISO/IEC 17029 (clause 9.7.1), the Programme specifies that the CAB (Conformity Assessment Body) is responsible for deciding whether or not to confirm the GIF Responsible Organization statement and to issue the assurance statement for sustainability reporting. The CAB make this decision with absolute autonomy and accountability, based exclusively on the results of the Due Diligence. The decision is taken by persons who were not involved in conducting the due diligence or in reviewing the reports. Do you agree that this demonstrates the independence of the VVB from other actors in the program? If not, please specify your comments and suggestions, if any

(See Regulation Section 5)

1.7.12 Monitoring – Periodical Assessments

The Get It Fair Program requires organizations to agree to undergo a series of periodic assessments conducted by Assessment Teams appointed by the AVB with the aim of monitoring the trends in the organizations’ level of exposure to sustainability risks over time. The frequency of periodic evaluations is inversely proportional to the score obtained in the initial Due Diligence. Do you agree that these monitoring activities address the needs of Stakeholders (e.g.: banks, insurance companies, investors, buyers) interested in having updated information on the sustainability practices and results, as well as the reduction of exposure to risks that could lead to adverse impacts? If not, please specify your comments and suggestions, if any.

(See Regulation Section 7)

1.8 Part I: Other matters

1.8.1 Other matters

Are there any other issues you would like to discuss regarding the Get It Fair programme?
Ci sono altri aspetti che vorrebbe segnalare sul programma Get It Fair?