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Good transparency

By Elaine Cohen (BeyondBusiness) on February 24, 2009 at 3:43pm.


The Danske Bank report is a good endeavor and gives an overall good impression of an earnest approach to CSR and to reporting. There are good sections on financial literacy and SRI,  where Danske Bank has made progress.  At GRI ‘C’ application level, this report is  a pretty good job – in fact, it is probably at least a ‘B’ level report. The data that is missing is probably not material: for example, nothing on supply chain (planned for 2009), nothing about ethics assimilation process or whistleblowing  (though there is a good set of references including a code of conduct on the website). There is little related to maintaining high levels of compliance or breaches of customer privacy, the employee section is a little light on data, and doesn't really cover core issues such as remuneration, recruitment and employee development processes.

There are a few areas where I felt there could have been an opportunity to tighten up the disclosure … for example, the CSR management structure is headed up by CR Boards. The CR Boards report to the Group CR Board. But where the Group CR Board is in the organization structure, and who heads it up, is not disclosed. Maybe in Denmark these things are obvious. Guess I should have done that mind reading course after all! Another example is training:  the group does not report on employee training hours because: "Often training is an integral part of the job. Thus it is difficult to register training hours, and the number of hours of formal education would not reflect the actual number of training hours.” Hmm. I think there has to be a consensus that training is formal time dedicated to training, which may come in very different formats. The fact that people in Danske Bank apparently learn by doing should not be an excuse to decline to disclose.

Poor customer survey results for one subsidiary are explained by IT problems after systems migration to a global IT platform. This apparently had quite a significant negative effect on results. The case is presented honestly and clearly by Danske Bank – this is nice reporting and demonstrates Danske Bank's commitment to transparency in general. So many reports just give the positive headlines. 
When checking the environmental data, I felt there were some inconsistencies , so I wrote to Danske Bank with my queries. I got a very comprehensive response within 24 hours. I was VERY impressed. Transparency and stakeholder responsiveness at its best.

One final point which is not unique to Danske Bank: reporting results. Danske Bank justifiably take pride in the well-planned launch of their first socially responsible banking product in 2008  – a Parent Study Loan for students, who are "among the most financially vulnerable in our society". Sounds very positive. But what I miss is THE RESULT. How many students actually took that loan? What impact did that launch have? If Danske Bank or any other bank launches 500 products and no one takes the bait, then their positive impact remains low. Sorry, Danske Bank for using you as a guinea pig in this last point. Many of the most experienced reporters don’t manage to take that extra step to finishing the story and providing us with a measure of the result or outcome.   


Danske Bank produces a short report consisting mainly of narrative, with a factbook  containing data. Maybe too much data e.g. the number of documents which were sent to electronic customer mailboxes is a rather high resolution.  But, it's good transparency. Example:  the list of companies excluded from SRI activities and the explanation given. Most of the data is broken down by the individual countries in which Danske Bank operates, over a 3 year period.  However, for me, the factbook idea is not ideal and there is some duplication between the two. Better to have one 67 page report than two separate documents.  It would be easier to digest the data presented in the context of the narrative, rather than in isolation. 

This is one of the few reports which states a focused target readership: investors, analysts and corporate customers. That's good to know.


Danske Bank have done a credible job with this report. There is a clear attempt at transparency, including disclosure of the difficulties as well as the good news. Goals and achievements in each section are well stated. There is no assurance, but there is a kind of simplicity to the stories Danske Bank tells which makes this report both credible and rather charming. For example, the story of two departments who ran an environmental competition to turn off lights, computers and screens, reducing energy use by 12% in 3 weeks. Simple but credible. 


1. Integrate the fact book data into the CR report (selectively)
2. Scope the supply chain data and include in next report
3. Review  opportunities to report outcomes as well as activities, especially in the community and customer sections.

Elaine Cohen is the Joint CEO of BeyondBusiness Ltd, http://www.b-yond.biz/en, a leading CSR reporting and consulting firm in Israel, specializing in a wide range of consulting services for the development of social and environmental responsibility of businesses.