Canadian Institute for Business and the Environment
Fisherville, Ontario, Canada
Tel. 416 410-0432, Fax: 416 362-5231
Vol. 16, No. 5, August 30, 2011
Honoured Reader Edition

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Our theme this issue is reporting of Corporate Social Responsibility. We look at a number of recent corporate CSR reports, highlighting advanced aspects, as well as at the environmental guidelines of the Canadian Securities Administration for public companies. We look particularly at the issue of materiality, a poorly defined and somewhat abused but extremely important aspect of corporate environmental reporting, and integrated reporting, an approach which we recommend wherever and whenever it is practical. Corporate Social Responsibility Reporting may sound like a dry topic but by keeping our articles short and focussing on company activities we have done our best to make it interesting. Let us know what you think by sending a Letter to the Editor to No need to make the format fancy - a normal email is good enough to be a Gallon Environment Letter to the Editor! We'll publish a selection of those received.

This issue also comments on the abuse of Sustainable Development terminology, and proposes a solution. We look at waste management from the Netherlands and comment on a recent ad agency claim that, in Canada, "environment has fallen off the radar". We also suggest you take a look at more Gallon Environment Letter news and commentary at our new GallonDaily publication at

Our next issue will likely take a look at CSR and the Supply Chain, a topic that we plan to make much more interesting than it sounds!


Since the World Commission on Environment and Development popularised the term Sustainable Development in 1987 there have been many more attempts to redefine the term than there have been to support what the Commission originally intended.

The Commission, often known by the name of its Chair, Gro Harlem Brundtland, defined Sustainable Development as:

"Development which meets the needs of the future without compromising the ability of future generations to meet their own needs."

In that definition, on which we can be sure that the Commission of 22 people spent much time in discussion, there was nothing allowing for time limits, or reliance on future technologies not yet invented, or on giving priority to immediate economic well-being over future environmental security. However, the Commission made it clear that poverty is a major contributor to environmental degradation and that we must address poverty issues if we are to build a new global economy based on a platform of Sustainable Development.

Today we have national and international opinion leaders discussing such topics as sustainable mining, sustainable oil, and sustainable coal. The Dow Jones Sustainability Indexes list more than 1200 companies, many of which will almost certainly not be around in 10 years let alone providing goods and services to future generations. Clearly Sustainability as defined by Dow Jones and many others has very little to do with Sustainable Development as defined by the Brundtland Commission.

This presents at least two dilemmas. First, should we state that the term Sustainable must only be applied to actions which can be maintained at their current intensity for at least seven generations? Should society tell those industries that are reliant on non-renewable resources, such as those represented by the Mining Association of Canada, that they must not describe their activities as Sustainable and that to do so constitutes misleading advertising?
Second, how do we persuade our industry and government leaders to give priority to more sustainable opportunities for job creation and economic and social development. The current Keystone Pipeline, against which several thousand activists are currently protesting in front of the White House, is a case in point. Construction of the most technically advanced and hence reportedly the safest pipeline in America is said to be going to create 20,000 short term jobs, linking Canada's oil sands to Gulf coast refineries and terminals. The company planning to build the controversial pipeline is listed on the Dow Jones Sustainability Index. Building the pipeline is unlikely to significantly increase US consumption of petroleum products and, despite arguments to the contrary, not building the pipeline is unlikely to substantially shut in tar sands oil as the Canadian government will almost certainly help Canadian producers ensure that their products have a path to market. My question: how does building, or not building, the Keystone Pipeline, contribute to Sustainability?

The problem seems to be that Sustainable Development has been shortened to Sustainability and we now apparently consider the two terms to be synonymous. GallonLetter's proposal is that the two terms need to be disentangled. Members of the World Commission on Environment and Development could issue a declaration that Sustainable and Sustainability are not appropriately used as shortened version of the term Sustainable Development and that the term Sustainable Development is only to be applied to activities that fit the original Commission definition. Mining and other non-renewable resource activities might then continue to be described as sustainable if they offered a small but significant improvement in environmental and social responsibility, something we all want to encourage, but they would not be Sustainable Development, because, truly, they cannot be. Describing mining and pipelines and other such activities as Sustainable Development, when they cannot possibly fit the definition originally presented in 1987, would constitute misleading advertising and could be prosecuted as such in all countries which have laws to ensure honesty in the marketplace.

Like all humans, I am not Sustainable Development though I hope I make a contribution to Sustainability.

Colin Isaacs


It is only a couple of decades past that the business sector talked about environmental reporting, providing stakeholders and shareholders with information about their environmental footprint. A few years after the Brundtland report was published it became fashionable in business circles to talk about Sustainable Development reporting. Until recently, few companies actually did it but many claimed Sustainable Development credentials for their annual environmental reports. Sustainable Development reporting covered environmental, economic and social indicators, though environmental and economic aspects were usually the only aspects to include much numerically rigorous data. Then companies switched to Corporate Social Responsibility reporting and today many of the companies disclosing environmental, social, and economic data are doing so under the rubric of CSR. Notwithstanding the business world's apparent preference for CSR, most of the major corporate reporting systems in use today still consider themselves to be reporting systems for Sustainability. That's the framework that is the theme if this issue of GallonLetter.


Export Development Canada, Canada's export credit agency which has in the past been criticized for providing financing to projects considered by some to be environmentally unsound, released its 2010 CSR report this month. One of the key initiatives for 2010 was revising the framework for environmental and social risk. (1) The framework now includes addressing climate change.

Among the uses of the framework include:
(1) The framework is called Environmental Policy, Environmental and Social Risk Management Framework Review Directive and Disclosure Policy. The Framework has been developed to consider international agreements and standards, including the OECD Common Approaches on Environment, the IFC’s Performance Standards on Social and Environmental Sustainability (IFC is an arm of the World Bank), and the Equator Principles, a voluntary code of practice adopted by the international banking industry in June 2003.

Environmental Programs Related to Climate Change

Through its EnviroExports program which provided support of $436 million for 223 companies, EDC helps companies whose products and services relate to climate change such as renewable energy products. One of these companies is DIRTT (Doing It Right This Time). DIRTT manufactures pre-engineered, movable modular walls for commercial interiors. The walls can be disassembled and reused resulting in less demolition and a lower carbon footprint. When Atlanta-based Autotrader moved its offices, it took its DIRTT walls to its new head office.

EDC also supports environmentally oriented domestic and international private equity funds. One example is investment in Enbala, a clean power technology company which enables large companies to adjust how their equipment demands electricity allowing electricity generation to operate at a most efficient manner.

Canada. Export Development Canada. Balancing Opportunities and Impacts. Corporate Social Responsibility Report 2010. Ottawa, Ontario: 2011.


RBC Financial Group says its sustainability reporting is multi-pronged including;
Paid subscribers see link to original documents and references here.


On October 27, 2010, the Canadian Securities Administration published CSA Staff Notice 51-333, Environmental Reporting Guidance, to assist public companies (issuers) to meet existing environmental disclosure requirements. While the provinces and territories in Canada regulate security, these have formed the CSA to provide support for harmonizing regulations across the country.

The intent is to provide investors with more complete information on environmental matters which the press release says "comprise a broad range of issues, including air, land, water and waste. These matters can affect issuers in several ways, including interrupting operations, resulting in material unplanned costs, providing new business opportunities, and potentially affecting reputation, capital expenditures, and a licence to operate."

Following consultations with investors, issuers and experts, the Notice provides guidance on compliance with disclosure rules in the following areas:
The guidance also provides examples of corporate disclosures.


One of the discussions in the Guidance is when disclosure about environmental matters are required. Materiality is the key factor in determining what needs to be disclosed. The test for materiality is "Information relating to environmental matters is likely material if a reasonable investor’s decision whether or not to buy, sell or hold securities of the issuer would likely be influenced or changed if the information was omitted or misstated." This somewhat subjective test for materiality for environmental matters is said to be consistent with materiality for financial matters as contained in the Canadian Institute of Chartered Accountants Handbook.

Some of the guiding principles in determining materiality in an environmental context include:
The notice relates to disclosure requirements set out in National Instrument 51-102 Continuous Disclosure Obligations. There are five key disclosure requirements in NI 51-102 that relate to environmental matters:
Disclosure about these matters, if material, is important as each provides insight into an issuer’s risk profile.

Role of the Board and Management

Boards are expected to ensure that management has done assessments for materiality in order to provide investors with information about environmental matters. Disclosures in documents should be consistent with this assessment. The material information in voluntary reports should also be disclosed in a timely way in securities regulatory filings.

Management needs processes to ensure that the information disclosed on corporate websites and in voluntary reports is consistent with requirements.

GallonLetter has checked many regulatory filings, press releases and other corporate information particularly at times when a company is in headlines due to toxic releases, explosions, and workplace deaths. Companies with good CSR programs will be quick to communicate about these but we have just as often been astounded to find that a company has failed to issue even a press release or has categorized the event as of no material significance in its filings. GallonLetter believes this guidance for materiality needs to become much more clear and unambiguous.

Paid subscribers see link to original documents and references here.
As part of its 2011 report on sustainability, Suncor Energy discusses topics and indicators critical to the company and stakeholders. Critical issues are covered in the print edition of the sustainability report with the web edition containing additional information. For example, land use of oil sands and water withdrawal are considered critical while charitable donations are discussed in detail only in the web edition. Charitable donations are normally considered a key element of Corporate Social Responsibility. Increasingly with web resources, companies are summarizing information in print edition, if offered, and expanding the information online.
The process for reviewing materiality includes an in-depth look at Suncor's objectives, programs and risk factors, media coverage, news releases, internal newsletters and ongoing dialogue with stakeholders including an annual stakeholder forum. Sustainability reporting from all Suncor unites is also reviewed.
After this initial step, a second step was taken for 2009 and 2010 which involved a Suncor team of grouping the issues into social, economic and environmental areas based on two criteria. Criteria 1 was how much control Suncor had over the issue and criteria 2 was the impact the issue had on Suncor and how much concern the issue raised in stakeholders.
Paid subscribers see link to original documents and references here.
Dow Chemical Company published a life cycle assessment of its portfolio of insulated sheathing products including a paper published in the peer reviewed Journal of Industrial Ecology in April 2011. The company's press release in August stated, "The report marks a significant milestone towards demonstrating Dow’s approach to sustainable business. In accordance with Dow’s 2015 Sustainability Goals, LCAs are conducted to understand the expected environmental benefits and tradeoffs associated with a technology, and to guide product development and implementation. Examining products from a life cycle perspective helps to ensure that anticipated sustainability benefits of Dow’s products can be achieved, and helps promote increased sustainability awareness among customers and manufacturers alike." Emissions saved due to use of the insulation products in buildings and pipe systems were said to be seven times Dow's direct and indirect greenhouse gas emissions in related to them. 
Dow's 2015 Sustainability Goals includes a commitment to report on progress "Presenting and/or publishing life cycle assessments that are validated independently by an external stakeholder, on existing or planned Dow products"
Improving building insulation lowers energy cost and GHG emissions. Mazor, M. H., Mutton, J. D., Russell, D. A. M. and Keoleian, G. A. (2011), Life Cycle Greenhouse Gas Emissions Reduction From Rigid Thermal Insulation Use in Buildings. Journal of Industrial Ecology, 15: 284–299. doi: 10.1111/j.1530-9290.2010.00325.
Paid subscribers see link to original documents and references here.
BC Hydro, a Crown Corporation, has integrated annual reports with triple bottom line reports into one, thereby providing economic, environmental, and social information in one report. "Reporting on the three bottom lines also allows us to benchmark our performance with other organizations to ensure we continue to remain in the forefront as a sustainability leader." The electricity company has the vision of "Powering B.C. with clean reliable electricity for generations." As is becoming more common, only web access is offered; there is no print copy.
In addition to the measures in the annual report, a comprehensive list of performance data is provided in the Global Reporting Initiative index on the website.
Paid subscribers see link to original documents and references here.
In 2005, Vancity, a Vancouver-based bank, commissioned a study to review integrated reporting, an approach which combines financial and sustainability reporting in one annual report. Susan Todd, the founder and principal of Solstice Sustainability Works Inc. (Burnaby, British Columbia) prepared the report with some of the following comments:
Todd concluded that integrated reporting "seems to be driven by its own irresistible logic and the internal benefits it delivers. Companies that have embraced sustainability take on integrated reporting because it makes sense to them and is the best way to reflect their holistic management approach. Through their efforts, both financial and sustainability reporting stand to benefit."
In 2010 Vancity issued an integrated report.
Paid subscribers see link to original documents and references here.
A new group called International Integrated Reporting Committee IIRC was formed in 2010. The reason for its formation was said to be due to the recent financial crisis. The financial crisis has shown people that capital markets seek short term profits at the expense of long term viability, not only of the single company but of entire sectors, countries and the global economy. Corporate disclosures failed to show the high risks in which companies were engaging, even when conforming to accounting standards.
The IIRC is chaired by Michael Peat, Principal Private Secretary to HRH The Prince of Wales and The Duchess of Cornwall with Deputy Chair, Professor Mervyn King, Chairman of the Global Reporting Initiative. Peat has been involved with The Prince’s Accounting for Sustainability Project (A4S) which created a prototype Integrated Reporting framework.
Members of the IIRC include representatives from A4S, the Global Reporting Initiative, the International Federation of Accountants, the main global accounting firms and bodies, the UN, the International Organization of Securities Commissions, the World Bank, the IMF, as well as businesses, investors, NGOs and academic institutions.
In October 2010, a workshop on Integrated Reporting hosted by the Harvard Business School attracted an international audience . A free ebook arising from that conference outlines the current state of thought on integrated reporting including the role of corporations in society, reconciling shareholder and stakeholder interests, drivers of corporate sustainability, need for standards for assurances and role of standards such as ISO 26000 “Guidance on social responsibility” to integrated reporting.
A discussion paper and regional roundtables are part of the planned IIRC process to develop a globally acceptable Integrated Reporting framework to present to the G20 meeting in November 2011.
Paid subscribers see link to original documents and references here.
A webinar of reporting trends presented by Mike Wallace, North American Director of the Global Reporting Initiative GRI touched on the use of GRI and some of the issues relating to CSR reporting in general.
Types of Reporting
Various "footprints" are addressed in different types of corporate reporting:
Where once companies used to think their only responsibility was to shareholders (and of course many ardent capitalists still think so) corporate performance and reporting is related to a number of stakeholders which can impact on the profitability and survivability of the company including:
Shareholder Initiatives
Investor groups which represent trillions of dollars in investment have been formed to foster responsible corporate performance. Some act on behalf of institutional investors; some focus on specific risks such as climate. Examples Wallace gave are:
Elements of the GRI Reporting Guidelines
Key topics include:
Each subitem within these topics is numbered so there is the potential to compare company reporting across the same items.
In 2006, the third revision G3, now the current version, of the GRI Sustainability Reporting Guidelines was launched following the launch of G2 in 2002 and G1 in 2000. Corporate reports will indicate this by including a statement something like prepared using GRI-G3. G4 is under development. and planned to be launched in 2013. Alcoa, Enel, GE, Goldman Sachs, Natura and Shell are sponsoring the development of G4 and Deloitte, Ernst & Young, KPMG and PwC which are auditors of GRI reports are providing advice.
Use of GRI
GRI has become more widespread as a reporting methodology over the years:
GRI charges for use of the guidelines on a sliding scale depending on revenue.
GallonLetter notes that GRI, like all other responsibility/greening initiatives, is imperfect. GRI is a voluntary program. Although it has a wide range of metrics, companies choose which of the metrics to report on and the GRI Index which points to where the information is available on that topic will (too often in GallonLetter's opinion) say "XXX Company does not report on this metric." or "N/R". Even when the CSR report is cited as providing that information, the data can be incomplete and definitely unsatisfying. Many of us tend to think that CSR reporting means the company is taking initiatives beyond compliance, that compliance is a bare minimum but some companies respond to the GRI metric on compliance e.g. "total number of incidents of non-compliance with regulations..." with "does not report."
The three levels called Application Levels, A, B, and C help to indicate whether more or less of the framework is addressed in the corporate reporting. If external assurance for the data in the report is provided, a plus is added becoming A+. Criteria set out which parts of the guidelines the company must report on to qualify for each level. The company can self-declare the level or can procure GRI to check the level; verifying the level does not gain a plus.
GallonLetter's parent company CIAL Group has helped companies with CSR reporting using the GRI framework. As long as the company doesn't regard reporting alone as the goal, the framework provides a good way for a company to chart a journey towards improving environmental, social and economic performance.
Paid subscribers see link to original documents and references here.
The controversy surrounding the oilsands industry monitoring and reporting too little information about their operations caused the Alberta Government to set up a panel to make recommendations on environmental monitoring, evaluation and reporting in the Lower Athabasca region. The government is accused by critics of being more interested in promoting the economic value of the oilsands than protecting the environment but the government press release stated that better environmental information will "increase public confidence in Alberta's environmental management systems." Among the recommendations of the panel’s report released in June 2011 is that a province-wide monitoring, evaluation and reporting system be set up with regional implementation using Alberta's Land-use Framework.
Pembina's Response to the Panel Report
"The environmental monitoring panel's recommendations are thorough. We urge the government to move swiftly to implement a new, more robust and transparent monitoring system." said Jennifer Grant, director of the Pembina Institute's oilsands program in a press release responding to the report. She suggests that insufficient environmental monitoring has eroded public trust and accountability and the government will have to protect the environment in order to show it deserves public confidence. GallonLetter thought her comment on date collection has relevance also to corporations monitoring and reporting, "It's important to note, as the panel did, that monitoring is just one component of natural resource management; you actually have to use the data to inform planning, regulatory decision-making and enforcement. You need the full package to get the job done — otherwise it's like having smoke detectors but no firetrucks or firefighters."
Alberta. Alberta Environmental Monitoring Panel. A World Class Environmental Monitoring, Evaluation and Reporting System for Alberta. The Report of the Alberta Environmental Monitoring Panel. June 2011.
Pembina Institute. Pembina reacts to Alberta environmental monitoring panel's report. July 5, 2011.
Companies often mention awards and recognitions such as listing on sustainability indexes like Dow Jones and Global 100 and various rankings such as those of Canadian-based Corporate Knights. Whether in press releases by the company or the recognizer or in corporate reports, these recognitions lend credibility to the company's own positioning in terms of sustainability.
BP has over the years been recognized by many accolades. Its reports under Global Reporting Initiative were at the highest level A+. Fortune magazine listed it as ranking among the highest in accountability. Dow Jones Sustainability Indexes DJSI recognized BP as a Sustainability Leader in its sector. The Gulf of Mexico incident is a major catastrophe of BP’s operations. It is one of several including major incidents such as the 2005 Texas City explosion (and a damning regulator report on BP's failures in due diligence) and Alaska pipeline leak.
BP Delisting from DJSI
As of May 2010, BP was delisted from the Dow Jones Sustainability Indexes where it was part of the World Index. The reason given for the removal was due to an index rule that allows removal due to "extraordinary events." The DJSI press release said that "The extent of the oil-spill catastrophe in the Gulf of Mexico and its foreseeable long-term effects on the environment and the local population – in addition to the economic effects and the longterm damage to the reputation of the company – were included in the analysis leading up to BP’s removal."
On the BP website with links to the annual meeting April 2011, BP included this statement: "Following the Deepwater Horizon accident, BP was de-listed from the Dow Jones Sustainability Index and the FTSE4Good Index. We understand why this has happened and will work towards restoring the respect of these organizations. In the meantime, we continue to engage in constructive dialogue with socially responsible investors."
In Gallon Environment Letter October 7, 2003, we commented that while these indexes they are popular amongst people in the financial services sector with interests in the triple bottom line and are better than nothing to show the kinds of tools available to companies for improving performance, GallonLetter is not a big fan of the Dow Jones indexes because they are based to a significant extent on company self-reporting rather than on independent review of performance.
BP illustrates for rankings of sustainability performance what Goldman Sachs and others do for financial performance: that there are gaps that should be addressed. Whether it is actually possible to close all the loopholes that innovative but self-serving money-makers will find without regulations strangling the other corporations who do meet reasonable standards of ethical and environmental performance is another question. While critics of BP want to dismiss the entire company as a pariah, GallonLetter thinks that BP with revenues larger than some nations is a complex entity. Many of its initiatives do lead in sustainability even though there are obviously some big problems in risk and safety management.
Paid subscribers see link to original documents and references here.
Two senior municipal waste management experts addressed a recent Ontario Environment Industry Association meeting, held in partnership with the Ontario Waste Management Association and the Municipal Waste Association (formerly the Association of Municipal Recycling Coordinators). Ton Holtkamp, the Chairman of the Netherlands Waste Management Partnership and Herman Huisman, Senior Advisor of the Waste Management Department of the Netherlands Ministry of Infrastructure and the Environment explained that the Netherlands:
The Netherlands is working with Turkey to set up similar initiatives in that country. Dutch companies are interesting in sharing expertise with Canada to help this country achieve similar waste diversion goals. Details can be found at                                     
Earlier this month, Toronto-based advertising agency Bensimon Byrne issued a press release headed "The Environment Takes a Dramatic Decline as an Issue of Importance to Canadians". Jack Bensimon, president of Bensimon Byrne, was quoted in the periodical Marketing Daily as saying that, since 2008, “the environment has fallen off the radar". GallonLetter begs to differ, suggesting that even the data in the Bensimon Byrne report do not support such extreme statements.
Bensimon's analysis suffers seriously from only having two data points, one from July 2008 and one from August 2011. In our opinion, two data points is hardly enough to establish a trend. Among our other issues with the analysis of the poll:
1) In 2008, the pollster asked three general questions about the economy before asking questions about the environment. In 2011, the pollster asked five questions, including two very specific questions about the respondent's personal financial situation, before asking about the environment. If you have just been asked questions such as "How would you say your PERSONAL [qv] financial or economic situation is compared to one year ago?" and "How do you expect your PERSONAL financial or economic situation to be one year from now - compared to what it is like today?" it is not surprising that a percentage of respondents would be immediately more concerned about spending money on the environment than if they had not just been asked those questions.
2) In 2008, in response to a question about how important the environment is to the respondent, 59% replied important and 34% responded somewhat important. For reasons unknown to GallonLetter, the response options to the same question had been changed for the 2011 poll: this time, to the same question, 49% responded very important and 46% responded somewhat important. What is the impact of changing the options from important, somewhat important, etc., to very important, somewhat important, etc. Clearly fewer people would answer Very important than would answer Important. Is this an attempt by Bensimon Byrne to fudge the results? If government had done this, there is no doubt that such an accusation would have been made. Note also that in 2008 the total of important plus somewhat important was 93%. In 2011 the total of very important plus somewhat important was 95%. Hardly "disappearing off the radar" as Bensimon was quoted as saying!
3) Bensimon Byrne makes much of the decline in the percentage of respondents who say they are Very Concerned about the environment from 38% in 2008 to 27% in 2011. But the number of respondents who are not at all concerned about the environment fell from 18% in 2008 to 8% in 2011, suggesting that in fact many more Canadians have some degree of concern about the environment in 2011 than had some degree of concern in 2008.
4) On all of the environmental issues (clean water, waste and garbage, protecting wilderness, promoting locally grown food, etc) that were covered in the Bensimon Byrne poll in both 2008 and 2011, the numbers who described the issue as important or somewhat important have remained the same since 2008, within the margin of error of the poll. Hardly a crashing decline in public concern about environmental issues. Indeed, on stopping genetically modified food, the number of respondents who described that as important or somewhat important increased from 74% in 2008 to 83% in 2011.
5) The question was asked When you are making purchases do you think about the environmental impact? In 2008, 32% responded Most of the time, compared to 25% in 2011. In 2008 48% responded Some of the time compared to 45% in 2011. Given that the terms Most of the time and Some of the time are purely subjective, and respondent's interpretation of them may well have changed, we suggest that even these two data points are hardly enough with which to declare a substantial trend.
6) The poll also reports that 91% of respondents recycle all paper, cans and plastic almost always or often (this is not supported by data from municipal recycling collections); 77% buy energy saving bulbs almost always or often (again not supported by sales data); 69% buy locally grown food almost always or often; and 58% have changed household cleaning products to non-toxic green products almost always or often. Again these data suggest more of an entrenching of green purchasing than the "falling off the radar" that Bensimon Byrne is trying to sell.
Contrasting with the Bensimon Byrne Poll:
>A July 2010 national opinion poll conducted by Angus Reid found that 66 per cent of Canadians think the government is paying too little attention to the environment.
>A December 2009 Harris/Decima poll found that 64% of Canadians believe that environmental initiatives should remain as a high priority even as the economy weakens.
>An August 2009 Harris/Decima poll found that 71% of respondents said environmental conservation is more important to them than it was a few years ago.
GallonLetter suggests that the Bensimon Byrne interpretation of the data is just plain wrong. However, to provide a numerical context, the data do show that environment is of concern to many more people (49%) than voted Conservative (39%) in the recent federal election. GallonLetter challenges Jack Bensimon to declare that support for the Conservative Party of Canada has "fallen off the radar"!
The two Bensimon Byrne polls are available at
(click on August 2011: Environment) and (click on July 2008: The Impact of Environmental Issues).
In its annual fiscal report ending March 2011, Niko Resources traded on the Toronto stock exchange and based in Calgary stated "In January 2009, the Company announced that the Canadian authorities were engaged in a formal investigation into allegations of improper payments in Bangladesh. The Company cooperated in the investigation, which was concluded on June 24, 2011. The Company pleaded guilty to one count of bribery under the Corruption of Foreign Public Officials Act, was fined Cdn$9.5 million and is subject to a 3-year Probation Order. In early 2009, the Company adopted a full anti-corruption compliance program."
Federal Court in Calgary had ruled that the company had bribed the Bangladeshi minister of energy and mineral resources in regard to a blowout at a natural gas well. The minister quit in 2005 because of the bad press about the bribe.
And yet in last year's annual report, the company's disclosure of risk factors focussed not on its own risk of prosecution for bribery but, "The Corporation may be at a disadvantage in that it may be required to compete against corporations or other entities from countries that are not subject to Canadian laws and regulations, including the Corruption of Foreign Public Officials Act (Canada) (or similar legislation of other jurisdictions, including the United States Foreign Corrupt Practices Act). Residents or nationals of countries not subject to such legal regimes may offer inducements to foreign governments and foreign public officials to entice such governments and officials to deal with them to the disadvantage of the Corporation."
Paid subscribers see link to original documents and references here.
If you find GallonLetter to be useful or enjoyable you may also find value in our new GallonDaily newsletter, focussing on current environmental and sustainable development news and commentary of particular interest to the greening of business. You will find GallonDaily at with new short articles and links generally posted almost every weekday and available in an archive for your future reference. Recent articles include:
As with GallonLetter, we welcome your comments and will publish a selection of those which we judge likely to be of interest to our readers. GallonDaily comments can be posted immediately following each article.
You can wait for perfect conditions or you can do the best with what you have now.
Jack Layton, Canada's Opposition Leader, New Democratic Party
Quoted by Mike Layton, speaking at his father's funeral in Toronto August 27, 2011 in telling the story of going out on a sailboat for the first time with his father giving him basic sailing instructions. When the wind died down, Mike had said maybe they should have gone sailing at a better time.
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