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    • As Wageningen University and Research (WUR) we greatly appreciate and strongly support FAO’s efforts on incentivizing and measuring the private sector’s contribution to achieving the SDG’s. This initiative is very much in line with WUR’s efforts for measuring and developing KPI’s for food systems investments, the work of the sustainability consortium and WUR’s ambitions to monitor and digitalize impacts of investments in biodiversity.

      For the private sector, the development of an ambitious set of indicators to measure the contribution to the SDG’s is of great value as most individual business are too small themselves to undergo this exercise and the business community will greatly benefit from a larger attempt to standardize indicators and make them comparable for benchmarking and monitoring purposes.

      1. Scope

      • Are the most relevant sectors and areas with respect to the private sector’s impact on the SDG agenda covered? Are the associated indicators adequate to measure private sector entities’ contribution to the SDGs? If not, where are the gaps? Are there any indicators included which are superfluous and why?

      WUR would like to advise that in food value chains also the restaurant, hotel and food services industry has a large impact on food systems, in particular where it comes to reducing food waste and circularity of food systems.

      # Number of sustainable inputs used

      Animal welfare should be extended in it’s set of indicators regarding health plans, use of antibiotics, and general food safety issues, which however, could possibly be replaced with GFSI or other certification schemes applied.

      • The framework is food-centric for the downstream sectors (food processing, food wholesale and food retail), and the scope of the guidance at the production level only includes crop and livestock production as well as aquaculture. Is the inclusion of aquaculture but not fishing the right approach given the similar impacts of aquaculture with other types of agricultural production? Should the framework be applicable to the forestry sector and if so, which aspects should be considered?

      In our view, to be more comprehensive, the framework should include both, the fishery and forestry sectors.

      • For certain sustainability issues, the performance of an entity cannot be assessed without going beyond the entity’s direct operations. Some indicators take into consideration reporting entities’ relationships with their suppliers or suppliers’ impact in the reporting entity’s overall performance:
      1. Indicators related to reporting entity’s relationship with suppliers: A.5.1 Proportion of local procurement, A.5.2 Fair pricing and transparent contracts,
      2. Indicators related to impact of suppliers: B.1.4 Water Management practices, B.2.3 GHG emissions (scope 3), B.2.4 GHG Emissions management, B.7.1 Land conversion, B.7.3 Sustainable use and conservation of biodiversity, C.4.2 Incidence/frequency rates of occupational injuries, C.5.1 Incidents of non-compliance with child labour laws, C.6.3. Non-compliance in food safety and food quality, C.7.1. Non-compliance with land tenure rights regulations, D.2.1. Amount of fines paid and payable due to corruption-related settlements, D.3.1 Management of risks to people, planet and society through supply chain due diligence. For the other indicators, entities are encouraged to assess and report on suppliers’ performance alongside their own reporting.

      Does this approach capture the relevant sustainability issues related to suppliers? Is it clear where reporting entities need to be requesting information from suppliers?

      WR provides an extensive framework and adequate tools on product sustainability and impact in the supply chain through the website of The Sustainability Consortium – Sustainable Products for a Sustainable Planet.

      3. Feasibility

      • Do private sector organisations have access to the type of data required to assess performance against the indicators? If not, is it feasible for them to collect it?

      Our experience is that smallholders do generally not have this information available, but are keen to know. Agreements on SDG’s are often made on industry level. If access to internet is available a number of indicators can be derived from digital technology. Wageningen is currently working on accessing these data for sustainability purposes. https://research.wur.nl/en/publications/tien-miljard-monden-hoe-gaan-we…

      6. Adequacy of specific indicators

      • C.1.2 Average hourly earnings of all employees: Would it be better to formulate this indicator as ‘Percentage of employees and other workers paid above a living wage, disaggregated by occupation, gender, age, and disability status’?

      Generally the minimum wage or living wage indicators are more important than average wages. However, these can fluctuate strongly and should include also non-permanent employees who are more at risk.

      If the purpose of this indicator is to measure progress towards reducing poverty and improving livelihoods a minimum approach should be used.

      • C.6.3 Non-compliance in food safety and food quality: Is it relevant to include incidents of non-compliance with GFSI certification as part of this indicator?

      Generally it is not advisable to use one concept or certification system only. There are many comparable national and international standards. In recent times a number of certification systems also recognise progress towards food safety standards, which should be acknowledged.

      • D.3.1 Management of risks to people, planet and society through supply chain due diligence: Does this indicator capture well entities’ institutional efforts and commitments to identify and address social and environmental risks along the value chain?

      This is a very broad indicator with many interdependencies and it is unclear what causes progress towards SDG’s in this indictor. Therefore separate indicators should be used.

      The ESG framework is more developed and delivers widely available data.