Irish Life & Permanent (IL&P) is the largest life assurance and residential mortgage lender in Ireland, with a retail banking arm. Headquartered in Dublin, the group has over 150 offices and 5,000 employees, mainly in Ireland with a small operation in the UK. This is the sixth report from the Group, at application level B+ of the GRI framework. It is short, crisp and focused. It's clear, to the point and flows well. It delivers a modest level of transparency.
The IL&P report is a "doing things right" report rather than a "doing the right things" report. In other words, IL&P's presentation of their 2009 CR performance focuses squarely on the direct impacts of their operations. Laudable though this is, it is somewhat below expectation given this company's long history of reporting. The potential of a business such as this to offer game-changing products and services in the insurance, banking and mortgage markets that lead to more sustainable customer offerings is not hinted at. Similarly, the management of risk – the core business of an insurance company – does not feature as an element of strategy in this company's CR program. Chairman Gillian Bowler says " …. the shape of the financial services industry in Ireland is changing and over the next year or more, new solutions and structures will emerge and we are determined to play a role in shaping those solutions." I would have welcomed hearing about just how Irish Life is planning to do that, and whether those solutions will be driven with a sustainability mindset.
The report is nicely set out and written in Plain English. This is an area where Irish Life excels, having received the 2009 overall winner award from the Plain English campaign, which exists to drive out gobbledygook, jargon and misleading public information from all forms of written communication. This is clearly something the financial services and insurance sectors could benefit from, and Irish Life has indeed produced a gobbledygook-free report. However, in leaving out the gobbledygook, Irish Life also leave out critical content that I would have welcomed reading. The report does not include Irish Life's approach to CR Strategy, there is no mention of ‘materiality’ and no indication of what is discussed with stakeholders. The four key sections – marketplace, workplace, community and environment – cover Irish Life's operations selectively. The marketplace section, for example, is almost exclusively a testimony to Irish Life's customer service, presenting customer satisfaction scores, survey results and awards received. Of course, great customer service is essential for a sustainable business, but we would expect a sustainability report to address impacts on customers through the type of products offered and the way these are delivered. Beyond Plain English and web-site accessibility, this is not addressed. The Workplace section covers recruitment, health and safety and training. A nice touch is the offer of workshops to help employees through the financial downturn, which includes topics such as managing personal finances, something that a financial services company should be good enough at. The environment section is positive, and includes a disclosure about the inability of the company to embed an environmental management system, which turned out to be more complex than they had first thought. This is an important inclusion and serves to help us appreciate the challenges of changing practices and culture in a business.
The report does not include commentary on performance against previous targets, and sets no targets for future years.
The report is, as mentioned above, clearly written and logically structured. It contains a GRI index and is easily navigable. Stakeholder engagement is covered on one page which describes the "type of engagement" with different stakeholder groups. This is rather elementary and doesn’t really reflect engagement but simply points of contact. "Meeting suppliers in the normal course of business to agree contracts", for example, is not necessarily a form of engagement. IL&P does not appear to have developed a considered approach to stakeholder engagement. The report is supplemented by additional information on the company's website, but the GRI index reference is simply "web" so it is difficult to find specific information.
This reports sticks very closely to the GRI framework, providing data and commentary in a fairly mechanical way against the clauses and indicators selected. It's slick and professional. There is evidence of solid basic accountability and in those areas IL&P selected to report on, there is good, direct commentary supporting the data provided. However, this report lacks spirit and a sense of true commitment. It lacks depth in almost all sections, skimming the surface at a declarative level with not enough substantiation. The assurance statement which confirms the report is "balanced and accurate" is weak, especially since several of the GRI indicators noted as reported do not provide the necessary detail to meet the reporting requirement. There is no evidence that CR has become a way of life at Irish Life, remaining at the level of action items on the annual work-plan. Where and how and against what criteria Irish Life invests its funds is also not discussed – a major omission in my view - and how CR principles affect the way this business makes decisions is not clear. My sense is that Irish Life needs to get on board more boldly with Corporate Responsibility, and to reflect this in their reporting. It needs to be something which is part of the way they do business, not a project that is running alongside the business. The commitment and clarity this Company shows in addressing its key direct impacts should be leveraged to present a more holistic CR approach and report.
1. Develop a more fundamental CR strategy and disclose this in more detail
2. Include discussion of how funds are invested
3. Develop a solid approach to stakeholder engagement and report stakeholder feedback
elaine cohen is a CSR Expert, Sustainability Reporter and Joint CEO of BeyondBusiness Ltd, www.b-yond.biz/en a CSR reporting and consulting firm, specializing in a wide range of consulting services for the development of social and environmental responsibility of businesses.