THE SUNSHINE STANDARDS
The Sunshine Standards provide direction for corporate reporting to stakeholders. Stakeholders include employees, customers, communities, suppliers, and others who contribute significantly to the success of the corporation, or are affected significantly by its actions.
Four disclosure standards are grounded in one fundamental principle. The statement of standards is followed by an amplification providing examples and details.
These standards are designed to complement and extend “generally accepted accounting principles” issued by the Financial Accounting Standards Board and its predecessors, that currently guide corporate reporting to stockholders. Corporate reporting to stockholders and other financial investors is mandated by the federal government; stakeholders are no less entitled to full and fair disclosure.
A product of deliberations by organizations and individuals representing more than 5 million persons, the Sunshine Standards incorporate and unify disclosure recommendations previously propounded by other organizations with more specific emphases, such as the environment, workers, consumers, and neighborhoods (see the Appendix for background on formulation and development).
The Sunshine Standards may be quoted or
in full, with appropriate attribution.
- Justice Louis Brandeis
Compliance with the fundamental principle and four standards is mandatory for an entity to be identified as satisfying the Sunshine Standards. The following examples and details, while not incorporated into the mandatory standards, will represent appropriate and achievable disclosure for most companies. Additional disclosure will also be necessary for some companies and in unusual circumstances.
An annual “Corporate Report to Stakeholders” should be issued publicly by all larger corporations. In addition to being freely available for examination and copying at corporate offices, copies should be placed in city clerks’ offices, municipal libraries, and union offices wherever the company has major facilities. A complete copy should also be available on the Internet. The annual report should be supplemented by ad hoc reports as necessary to immediately apprise stakeholders of changes with which they may be concerned.
Form of the report is less important than content. For most companies the report should be divided into three sections for customers, employees, and local, state, national and global community. Financial reports may be incorporated by reference to Securities & Exchange Commission (SEC) filings publicly available on line.
The reporting format should consist primarily of text and
numerical disclosures; these may be supplemented with, but not replaced
by, graphs, charts, and illustrations. Comparative data, covering
a five-year period when possible, may be essential to place current
in perspective. Promotional and self-congratulatory material
not be included; it will dilute the reports, and may produce skepticism
regarding the accuracy and completeness of factual disclosure.
A. Measures of customer satisfaction appropriate to the company's products and industry, reflecting such data as customer satisfaction surveys, product returns, warranty claims, and product reviews by media and consumer organizations2. Actions brought by customers and regulatory authorities regarding products, services, and market practices
B. Risks of injury from normal usage
C. Noise, odors, and other nuisances or problems associated with use
D. Design for recycling
E. Biodegradability of products and packaging
F. Unusual life-cycle costs, including repairs, energy consumption, and disposal, that will be borne by parties other than the producer or seller.
G. Warnings, with appropriate detail, regarding unusual contamination and adulteration exposure and risks during production, shipping, marketing, and storage.
H. Emissions ratings, by specific model, for products that generate air pollution.
I. Content, additives, and treatments of foods and medicines, sufficient to allow reasonably informed customers to make rational market decisions and to protect themselves and their families. Appropriate descriptions may include information regarding genetic engineering, pesticides used on fruits and vegetables, hormones and chemicals used in growing and processing meat, and substances in cosmetics and personal grooming products to which customers may be allergic. (Disclosure needs regarding product content and treatments will evolve with new technology and chemistry, and as knowledge of diet, nutrition, and health advances.)
J. Recall and additional safety-related information for automobiles, trucks, farm equipment, vans, campers, and other vehicles and equipment when their use may represent a safety threat. Disclosure should indicate when and why the product was recalled, and whether the problem has been corrected in the specific unit being offered for sale.
K. In general terms, provide disclosure for:(1) Significant characteristics of products that are expensive or are purchased only infrequently.
(2) “Well-hidden characteristics”: those product qualities, regardless of expense or purchase frequency, that remain hidden even after use — such as amount of toxic chemicals and nicotine in cigarettes, nutritional value of foods (already required), and potentially hazardous properties not evident upon inspection.
A. Comprehensive record of claims, legal, and regulatory actions relating to products and services, including product liability, injury, and wrongful death claims, covering all jurisdictions for previous five years. Describe each claim and its disposition. Classify claims by specific product to facilitate consumer market choices.3. Social responsibility information
B. Indictments and citations for regulatory violations during previous five years, giving details of each incident and resulting penalty, settlement, or other disposition.
Customers may legitimately base purchase decisions on considerations of corporate social responsibility, such as working conditions under which products are manufactured, sustainability of production and business methods, or activities of a company’s political action committee (PAC). Decisions that may appear to be “merely” economic are, to many customers, reflections of personal — and sometimes intense — religious, moral, political, and social convictions. To intelligently exercise the sovereignty of the marketplace, customers may require information illuminating a company’s social responsibility.
When customers express a reasonable desire for social
information, it should be provided through full and timely
While one may disagree on the issues of customer concern, participation
in a free market economy carries with it the obligation to comply with
the market’s requirement for adequate disclosure.
1. Employment security and stability
A. Information regarding facility closings, including:2. Health and safety risks, classified by site(1) Statements of policy on helping affected employees in finding suitable employment, transferring employees to other company locations, and assisting with the sale of workers' homesB. Layoff record for previous five years, showing for each layoff event:
(2) Information on positions available at other company sites
(3) Summary of record on facility closings over past five years – where, when, how many employees affected, how many successfully relocated, how much notice was given(1) SiteC. Unemployment compensation rating and record
(2) Number of employees affected by department and by employment category (e.g., managerial, clerical, production, support)
(3) Total person-days involved in the layoff, along with quartile days off (e.g. “Of 180 employees affected, 75% experienced 47 or more days off, 50% were off over 62 days, 25% were off over 78 days, and 20% were never recalled.”)
(4) Statement of policies regarding employment security and layoffs. For example, does the company seek to maintain a no-layoff policy, or are layoffs acceptable for such purposes as managing inventories or improving short-term profits?
A. Employee exposure to radiation, noise, temperature and humidity extremes, chemicals, fumes, toxic substances, fibers, and emissions, and to inhalation of smoke, chemicals, and dust3. Employment equity, security, and diversity
B. Hazards associated with use of tools and equipment, including risk of repetitive motion injury and radiation exposure from computer monitors, laser printers, televisions, and microwaves
C. Unusual threats specific to pregnant women
D. Data on past accidents, injuries, illness, and medical complaints, classified by job, department, date, and nature (reports to the Occupational Safety and Health Administration may include some of these data, but OSHA reports do not provide sufficient information for workers to protect themselves in making employment decisions)
A. Data tabulated for previous five-year period and classified by gender and race, showing:4.. Employee grievances(1) Hires and promotions during the year, and number by position classification at year-end (reports to the Equal Employment Opportunity Commission may include some of these data, but EEOC reports do not provide sufficient information for workers to protect themselves in making employment decisions and, except with respect to larger federal contractors, are generally not public)B. Ratio of compensation, including benefits, bonuses, and stock options, for top executives to that for lowest level employees
(2) Average total compensation levels (including stock options and other benefits), broken out by job categories, such as top executives, other senior management, second-level management, middle management, line workers, clerical, and custodial. Other classifications may also be appropriate, such as professional, research, supervisory, or entry-level
C. Turnover statistics classified by department, job level, gender, race, and age
D. Promotions from within compared with external hires
E. Statement of company policy regarding payment of a living wage, and whether such policy excepts any geographical locations
A. Statistics on grievances filed by employees, classified by nature of grievance and office or agency with whom filed (e.g., human resources department, company “ombudsman,” labor union, government agency). Claims that, in the company’s view, are unsubstantiated, should nevertheless be tabulated; explanatory notes may be provided.5. Pension programs
B. Employment-related lawsuits (such as for discrimination or sexual harassment) filed, adjudicated, or settled during the past five years
C. A statement indicating whether mandatory arbitration is required as a condition of employment or retention
Extent to which past and current benefit liabilities are funded, contents of the portfolio, and changes in market value. (Some of this information may be available to the company in reports prepared under the Employee Retirement Income Security Act.)
6. Future plans
To the maximum extent feasible, disclose future plans and
that will enable stakeholders to prepare for and protect against
consequences of corporate actions. These actions may include
expansions, introduction of technology that may threaten employee job
plant relocations or closings, product discontinuation or substantial
and divestiture of units. Because their risk may be even greater,
employees, neighboring communities, customers, and suppliers should be
entitled to receive information provided to security analysts.
1. Company ownership information
Names, addresses, and number of shares held by the twenty largest shareholders excepting any shareholder with less than one-tenth of one percent of outstanding shares. Provide actual beneficial shareowner names rather than “street names.” (This information may be essential for decisions by communities considering tax abatements, industrial development bonds, and other special corporate benefits.)
2. Environment and sustainability
A. Material usage and waste3. Prior performance in response to special public benefits(1) Radioactive, toxic, hazardous, and dangerous materials used, transported, or stored, showing sites and routes. Provide periodic or continuous updates as necessary. (Some of this information is presently reported to the EPA.)B. Pollution emissions data
(2) Chemicals that pose a significant risk of cancer or of reproductive toxicity
(3) Estimated annual water consumption
(4) Annual quantities of waste and sewage expected to be generated by company operations, classified by risk to health and safety and identifying disposal methods and locations. Provide separate estimates of waste from consumption of company products.(1) Current estimates of air and water emissions, by specific site, category and quantity, along with actual emission for the previous five yearsC. Sustainability: statement of policies respecting sustainable development
(2) Data on penalties, settlements, and judgments related to environmental violations during the past five years
D. Recycling: material type and quantity of non-product output returned to process or market by recycling or reuse
A. Results achieved in response to corporate commitments, such as creation of a certain number of new jobs, made to obtain special benefits requiring public funds or resources; these may include enterprise or development zone status, tax exemptions, industrial development bonds, zoning exceptions, utility discounts, and modification or installation of streets or traffic controls4. Legal and regulatory profile
B. When special public benefits are predicated on new job creation, provide specific data on new jobs actually created, classified by type of work, number of employees, average compensation and benefits, and whether projected to be temporary or permanent
Legal and regulatory actions, civil or criminal, brought against the corporation in all jurisdictions during preceding five years. Describe the nature of claim or charge, parties involved, and status or disposition. Include charges settled by pleas of nolo contendere. Show fines or other penalties rendered against the company, or its officers and agents in their fiduciary roles.
5. Financial data
Financial information equivalent to SEC Form 10-K filings covering the past five years, plus current quarterly reports. (May be incorporated by reference to SEC filings publicly available at no charge on the Internet.)
6. Taxes paid
Taxes paid to all jurisdictions, classified by type of tax. When possible, report actual payments on a cash, rather than accrual, basis.
7. Materials sourcing
Geographic breakdown of international materials sources by dollar amount. Reasonable approximations are acceptable.
8. Facility construction data
Plant construction data important to community safety officials. Note whether asbestos, lead, or other potentially hazardous materials were used, whether there are known structural defects, how ground surface was prepared, and prior uses if known (for example, was the facility built on a waste dump?).
9. Vehicular activity
Estimated number of vehicles, annual mileage, and annual ton-miles projected to be driven in city/communities in which the corporation has significant activity
10. School impaction data
Potential school impact of children of employees, to facilitate planning by school officials. (Disclosure will be similar to data used by the federal government in providing impacted area assistance where there are large federal facilities.)
Breakdown of financial investments by location, with sufficient detail to enable citizens and policymakers to determine the extent to which the firm is supporting /local enterprises, and whether it maintains investments in countries with oppressive regimes
Corporate charitable contributions broadly classified by purpose, type, and location of beneficiary, with specific identification of communities in which the company has major facilities
13. Lobbying and political activities
A. Corporate contributions to political organizations at all political levels, directly or through political action committees (PACs), classified by party affiliation of the beneficiary
B. Names of all PACs established by the company, and amounts dispensed in contributions
C. Amounts spent on lobbying activities at all political levels, including payments to law or public relations firms for lobbying as well as amounts spent directly
D. Amounts contributed by the company to trade associations for special political or lobbying campaigns, over and above normal membership dues; the association should be identified by name
E. Amounts contributed to ad hoc political or lobbying organizations created for special campaigns; show recipient organization names
F. Amounts committed to “issue advocacy” campaigns, classified by issue
1. Statements regarding company adherence or nonadherence to:
A. Universal Declaration of Human Rights, particularly Article 23 concerning the right to form and join unions2. Amount and content of trade with countries that is officially discouraged as a matter of national policy (because of, for example, hostile relations or abuse of human rights)
B. International Labour Organization (ILO) Convention Number 29 on forced labor
C. ILO Convention Concerning Discrimination in Respect of Employment and Occupation
D. ILO Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy
E. Convention on the Elimination of All forms of Discrimination Against Women (CEDAW)
F. International Convention on the Elimination of All Forms of Racial Discrimination
G. Convention on the Rights of the Child
3. Foreign exchange generated and used, to permit an assessment of the extent to which the corporation is contributing, favorably or unfavorably, to our balance of trade
4. Major government contracts, by nature and dollar amount, and amount and nature of penalties for malfeasance associated with government contracts
Other stakeholders beyond those enumerated include financial
lenders, and suppliers. Corporations should give consideration to
whether additional information, beyond that enumerated here or
for public financial reporting, may be necessary to satisfy the
needs of these stakeholders.
|Great corporations exist only because
they are created
and safeguarded by our institutions; and it is our right and our duty
see that they work in harmony with these institutions. . . . The first
requisite is knowledge, full and complete; knowledge which may be made
public to the world.
Theodore Roosevelt, first message to Congress
The Stakeholder Alliance, a coalition of organizations and individuals representing more than 5 million persons concerned with the interests of corporate stakeholders, has developed the Sunshine Standards for Corporate Reporting to Stakeholders to provide guidance on disclosure expected from corporations in return for the privileges of (1) endowment with a public charter, (2) participation in a free market system, with accompanying rights and responsibilities, and (3) the substantial benefits extended to corporations by stakeholders and society.
These standards were initially synthesized from and informed by prior works, including:
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