Global Forum on Food Security and Nutrition (FSN Forum)

As part of the Fixing the Business of Food project for aligning the food sector with the SDGs (https://www.fixing-food.com/), the Columbia Center on Sustainable Investment (CCSI) and the Sustainable Development Solutions Network (SDSN) welcome the contribution of FAO's core indicators to efforts to measure the food sector’s contributions to the SDGs.

Attached, we provide constructive remarks with hopes of helping improve the methodology. We look forward to further collaboration and welcome any questions regarding our contribution.

Hello, FAO staff,

Although my opinion is not directly related to the above topics, it is important for the secondary indicators to emerge from them.

Known that, the food balance (FBS) methodology of FAO has been improved in many ways, but it seems that still has its disadvantages.

According to the new food balances (FBS), highlighted as the new loss module is a linear hierarchical algorithm that imputes for losses across the whole value chain up to and excluding the. The hierarchy is based upon commodity and country groups. In addition, much more use is made of web scraping, text mining, and academic/research articles and publications. Thus, the historical loss percentages in the food balances are consistently being revised based upon the new findings.

If we look at the relative losses in the example of potatoes for the country of India, we consider the data on old and new methodologies.

Known that, India is the world's second-largest producer of potato, after China. Together, both countries contribute 38 percent to the world's total potato production. According to the estimation of FAO of loss in potatoes and products for India, it can be seen that 23.3 percent of the amount of potatoes and products, that is lost from total production (see attached table 1).

According to information in the Report on the assessment of quantitative harvest and post-harvest losses of major crops and commodities in India, the total loss in potato is estimated at 7.32 percent for the study years 2012-2013. The conclusion is that there are significant differences between the data of international organizations and national organizations.

Another important and noteworthy aspect of this information for India is that the share of losses from the whole production quantity of potatoes and products differs significantly not only from its neighboring countries but also almost all other countries of the world (see attached table 2).

Moreover, in the new food balances (FBS) it is highlighted that an in-depth analysis has been carried out on the historical time series of stocks and a number of ‘unrealistic’ series (negative stock levels, or in excess of certain supply thresholds) have been discontinued and re-imputed, but it can be seen that there are still negative stock levels for some countries to the latest data.(see attached table 3)

Hurriyat Khudoykulova,

Freelance researcher (Ph.D)

Thank you very much for this opportunity to review the Supplement Guideline on Core Food and Agricultural Indicators for Measuring the Private Sector Contribution to the SDGs. I would like to make the following comments with regards to the adequacy of specific indicators (#6).

It is commendable that gender aspects are incorporated in various indicators, including the proportion of local procurement and the percentage of employees covered by collective agreements, across different (i.e., economic, social, and institutional) dimensions by asking to disaggregate data by sex. However, women’s empowerment perspectives can be further reinforced considering not just that women comprise over 37% of the world’s rural agricultural employment, but that women account for up to 80% of workers in the plantations or processing factories.

In this regard, it is particularly important that the private sector actors take gender-specific measures to mitigate health and safety risks for women, in particular pregnant and lactating women, including mental health and stress that is exacerbated by sexual harassments and assaults. It is not only a material topic of corporate social responsibility and the sustainability and stability of entity operations, but also a high financial risk given that more and more ESG investment funds consider gender equality as high priority.

The Indicator C.4.1 Expenditures on Employee Health and Safety exactly speaks to this point; however, it should be gender sensitive. It is currently a quantitative indicator that measures the entity’s related expenses, but entities could also report, for example, if they address the specific health, safety, and hygiene needs of women at work and while commuting to work with a qualitative indicator. (It would be difficult to disaggregate the expenditure data by sex.) Its methodology could build on the Women’s Empowerment Principles Gender Gap Analysis Tool of the UNGC (https://weps-gapanalysis.org/) (Q10, 11, and 12 are particularly relevant.)

May 1, 2021

TO: FAO

FR: NDDIET, BIODIVERSE FOOD STUDY, PANAMA

SUBJ: Core food and agricultural indicators for measuring the private sector’s contribution to the achievement of the Sustainable Development Goals

Sustainability is a natural component of our ecology. We are the only species that lives in an unsustainable manner. The United Nations Food & Agriculture Organization wants to know how to evaluate private sector sustainability contributions.

Here are my top 3 importance's that will indicate a more sustainable contribution from private sector agriculturists.

Switch from mono-culture style to natural fertilization making and diverse agriculture systems.

Sustainable energy resource investments, solar, small hydro and wind, etc.

Increases in diverse production.

I can only add that the more diverse and sustainable the operation, the better the produce dynamically and we know well through our study diverse nutrition = a higher quality of life and less suffering.

Brandon E.

Senior Research Person

Bio-dynamic Food Study, Panama

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.

The following are my two comments on the indicators provided:

1. While the cross cutting issues such as gender and age have been taken care of in some indicators (eg. D.1.2, D.1.3 etc), I am of the opinion that other cross-cutting issues like disability should also be considered. In addition, the cross cutting issues mentioned above (gender, sex, disability etc) should strongly be reflected across the indicators where possible and not just to some indicators.

2. There is a need to clearly indicate the role of the digital technology in measuring and/or assessing the indicators. Where possible too, utilization of digital technology in accelerating the outputs could also be measured.

Core food and agricultural indicators for measuring the private sector’s contribution to the achievement of the Sustainable Development Goals

Q-Are the associated indicators adequate to measure private sector entities’ contribution to the SDGs?

Answer: The report is quite comprehensive but I feel private sectors institutional characteristics including innovativeness needs to be captured

Q-If not, where are the gaps?

Answer:

1. Expenditure on technical training of workers as proportion of revenue;
2. Sources, uptake and funding of technologies/information/innovation development and dissemination;
3. Community service or compensation to community of operation;

Q- Would it be helpful to include the specific list of indicators which apply to each type of production, e.g. aquaculture, livestock, crop production?

Answer: No there should be a standard format that can be adopted by all the sub-sectors for ease of reporting.

Best regards.

Margaret.

We’ve been encouraged by the feedback received to date both on the forum itself and directly by email, where contributors have highlighted the importance of not just capturing the ‘avoidance of harm’ by the private sector but also the significant positive impact that is being made. On a number of the specific questions we’ve posed, it’s been helpful to hear the views expressed on inclusion of aquaculture and forestry and the highlighting of some issues which contributors thought should receive greater attention like gender, mental health and food quality. This feedback is extremely useful as we seek to refine the indicators and ensure that they are fit for purpose and we look forward to receiving additional contributions over the coming weeks!

FAO Core food and agricultural indicators for measuring the private sector’s contribution to the achievement of the Sustainable Development Goals – World Benchmarking Alliance (WBA) Feedback

Methodology link

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?

We welcome this initiative and strongly support FAO’s efforts on incentivizing and measuring the private sector’s contribution to achieving the SDGs. These efforts are in line with WBA’s mission and vision.

Generally, we appreciate the broad approach in terms of sectors and areas covered by the core indicators. As such, we see a high level of alignment between FAO’s core food and agriculture indicators and the methodology (and indicators) for WBA’s Food and Agriculture Benchmark. We appreciate this alignment, ensuring basic synergies between both frameworks as well as consistency on metrics required. We view this as an important basis for further conversations between FAO and WBA, and looking at potential collaboration on driving the agenda for private sector engagement on the SDGs.

Going through the core indicators, the following questions have come up:

• Sectors covered: The scope of the framework does not include food service and restaurant chains. Why is this sector not included? WBA’s Food and Agriculture Benchmark considers food service and restaurants key players in the food system transformation agenda.
• Animal welfare: This topic is not covered. As we consider animal welfare a key issue for private sector action - is there a reason why it is excluded from the core indicators?
• Promoting sustainable and healthy diets: Indicator C.6.2 contains multiple elements that address different aspects of promoting sustainable and healthy diets. For example, activities related to responsible advertising and promotion of healthy foods. Both elements require separate data points, and as such can both form a separate indicator on responsible marketing activities. Two indicators, one that assesses companies’ efforts on improving the nutritional quality of products and one on (commercial) food promotion practices, can strengthen the focus on these two key topics.
• Forced labour/modern slavery: this topic is excluded except in terms of child labour. As this can be considered a key aspect in many agricultural supply chains, WBA’s Food and Agriculture Benchmark includes two separate indicators in these topics. Why was it excluded from the core indicators?
• Referencing: we much appreciate the referencing of the high number of sources used, including WBA sources. As our materials (notably the benchmark’s methodology) evolve over time, it may be useful to further specify the documentation used:
  
  World Benchmarking Alliance (WBA) 2021, Methodology for the Food and Agriculture Benchmark: A roadmap for corporate action, indicator [xyz]. Available at: https://www.worldbenchmarkingalliance.org/research/food-and-agriculture-methodology/

• 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?

If fishing activities are not included in this sectoral guidance, are you planning to develop a separate guidance for that sector? Or maybe refer to an existing standard to guide companies in the industry?

WBA’s Seafood Stewardship Index assesses the performance of the seafood industries in achieving key SDGs. The methodology includes key topics for the industry in moving to a sustainable sector.

• Would it be helpful to include the specific list of indicators which apply to each type of production, e.g. aquaculture, livestock, crop production?

To increase the understanding for stakeholders, including companies, it could indeed be helpful to have an overview of the applicability of indicators to key segments of the food value chain. Further, it could also be helpful to have an overview of the most material/relevant indicators for each type of production.

• 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:
   1. A.5.1 Proportion of local procurement
   2. A.5.2 Fair pricing and transparent contracts
2. Indicators related to impact of suppliers:
   1. B.1.4 Water Management practices
   2. B.2.3 GHG emissions (scope 3)
   3. B.2.4 GHG Emissions management
   4. B.7.1 Land conversion
   5. B.7.3 Sustainable use and conservation of biodiversity
   6. C.4.2 Incidence/frequency rates of occupational injuries
   7. C.5.1 Incidents of non-compliance with child labour laws,
   8. C.6.3. Non-compliance in food safety and food quality,
   9. C.7.1. Non-compliance with land tenure rights regulations,
   10. D.2.1. Amount of fines paid and payable due to corruption-related settlements,
   11. 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?

Depending on where the company sits on the value chain, there are a few more topics that are related to the impact of suppliers. For example, in the WBA Food and Agriculture Benchmark, we also ask about impact of suppliers on the following topics, in addition to the ones indicated above:

• B.1.1 Water stress: if downstream companies source products produced in water-stressed regions, and if they engage with their suppliers.
• B.9 & B.10 Fertilizers and pesticides: if downstream companies expect their suppliers to reduce and/or optimise the use of fertilizers and pesticides.
• B.7 & B.8 Biodiversity and soil: if downstream companies expect their suppliers to adopt practices that improve soil health and agrobiodiversity.

2. Clarity

• Is the supplementary guidance clear in terms of type of private entities targeted and reporting rules?

In some cases, there is overlap between indicators, such as B.7.1. land conversion and B.7.3. sustainable use and conservation of biodiversity if companies were to report on deforestation/conversion-free targets. Acknowledging that the topics are highly connected, would it be relevant to focus B.7.3 on sustainable use of biodiversity (through sustainable agriculture for example), and focus conservation of biodiversity (through no-deforestation commitments for example) under B.7.1 and B.7.2?

• Can entities easily evaluate if their activities and the commodities they purchase, produce, process, manipulate and/or sell are in scope for each indicator? If not, how could this be improved?

The scope of sectors included across p. 7-9 is a useful overview for the general framework. The “scope” section for each of the indicators is also a good guidance for companies. It would be great to have an overview of the indicators and their associated scope for each of the sectors.

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?

For the indicators as part of WBA’s Food and Agriculture Benchmark, initial research has been done to ensure availability of data and applicability of indicators. There is strong divergence between industries/sectors and companies on the level of complexity of data needs as well as availability depending on the indicator.

• Do companies have country-level information in order to provide disaggregated data by country to feed into SDG monitoring/reporting?

Many companies collect such data. Much divergence exists around quality, depth and public availability of such data, and strongly depends on the topic.

4. Ease of use

• Does the guidance make it easy enough for private sector entities to understand how to calculate their performance against each indicator? If not, where is improvement needed?

The indicators provide great depth in terms of understanding the issue, as well as providing guidance towards measuring impact. However, certain indicators could be strengthened by referencing existing initiatives that already support private sector action. For instance, indicator B.1.2 on water stress can reference existing tools such as the WRI Aqueduct Tool or the WWF Water Risk Filter that provide companies with the database to map their water risk footprint.

• Is there sufficient supplementary guidance in terms of links to additional materials and definitions?

5. Qualitative vs. quantitative indicators

• Are there ways to make any of the qualitative indicators quantitative and how? Qualitative indicators are:
• A.2.3 Financial Risk Management
• A.5.2 Fair pricing and transparent contracts
• B.1.4 Water management practices
• B.2.4 GHG emissions management
• B.7.3 Sustainable use and conversion of biodiversity
• B.9.2 Management of pesticides
• B.10.2 Management of fertilizers
• C.6.1 Food labelling
• C.6.2 Practices promoting sustainable healthy diets
• D.3.1 Management of risks to people, planet and society through supply chain due diligence.

1. For example, would it be preferable to replace the indicator in C.6.2 which focuses on practices with an indicator on the percentage of the entity’s marketing budget spent on promoting healthy foods?

Not replacing, but it could be useful to single out responsible marketing and create a separate indicator that focuses on both regulating negative practices and enhancing positive marketing strategies to promote healthy eating. In this way, a quantitative indicator on the percentage of the entity’s marketing budget spent on promoting healthy foods would be extremely relevant and valuable.

Indicator C.6.1 can include quantitative metrics. Next to acknowledging the countries in which food labelling in regulated by country legislations, companies can disclose the % of products for which they have rolled out labelling commitments beyond legal compliance (ideally, covering all the relevant markets where the company operates).

Examples

• The company has X% of its products (or sales values) compliant to national regulations/Codex Alimentarius in X countries in which it operates.
• The company has rolled out supplementary labelling schemes for X% of products (sales values) in X countries in which it operates.

Many of the environmental indicators in WBA’s Food and Agriculture Benchmark require companies to report on their targets towards reducing their impact on environmental issues. In some cases, this is a mix of qualitative and quantitative data. For example, on soil health, we expect companies to disclose their commitments/policies to improve soil health, but we also ask them to disclose quantitative data on their impact on soil health, for example, through % reduction of land affected by erosion, % of land under regenerative agriculture, etc. Similarly, for downstream companies, the benchmark expects companies to report on the proportion of food it sells that is produced under recognised environmental schemes that replace harmful pesticides with alternatives and optimises fertiliser use.

6. Adequacy of specific indicators

• B.7.1 Land conversion: Do the three sub-indicators address the issues with land conversion as related to the achievement of SDG 15?

It is unclear under indicator B.7.1 on land conversion if downstream entities who source high-risk commodities are required to report on this. Such entities have a huge impact on land conversion through their sourcing practices, and this should be made clearer in the indicator. It might also be useful to specifically call out the main high-risk commodities (such as beef, soy, palm oil, etc.) that are responsible for majority of land conversion, and are found in the portfolio of most global food and agriculture companies. Moreover, the land conversion indicator could be strengthened by including guidance for companies to set targets to eliminate land conversion of natural ecosystems, and report performance against the targets.

• B.7.2 Habitat area protected: Where there is no natural habitat in the reporting entity’s production area, should there be a requirement for reporting on restoration or ‘rewilding’ to create habitat?

A requirement may be too strict when a company does not have any impact on natural habitats. For WBA’s Food and Agriculture Benchmark, companies will not be assessed on this topic, who do not produce/source high-risk commodities, which are among the major threats towards natural habitat destruction.

• 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?

It depends what the purpose of the indicator is – the indicator would be entirely different if it referred to Living Wage.

• 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?

We consider the disclosure on the % of companies’ operations (n of plants in all countries in which the company operates) and % of suppliers audited and certified by GFSI (or other independent and globally accepted third-party certification) more relevant than reporting on non-compliance incidents. The former is a measure of how the company supports its suppliers with implementing food safety requirements, which we deem as the key element of our food safety indicator.

• 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 indicator seems quite broad. It may be difficult to capture human rights due diligence and environment due diligence in one indicator. Is it possible to split or clarify the objective of this indicator?

I would like to draw your attention on aquaculture as a specific form of farming system, and with specific value chains.

Aquaculture is included in the guidance, but this sector is quite specific compared to terrestrial animal rearing and farming systems and would need to be better accounted for, especially under the scope of "agriculture production". For example, under the Environment dimension, in relation to Soils and Fertilisers  aquaculture is excluded, when in fact it can have an impact on soil quality/degradation (e.g. shrimp ponds), and some freshwater pond farming system do rely on fertiliser use and fertilisation.

I have not delved into all the details of the document and indicators, but more specific comments with regards to aquaculture are included in the attachment. 

Best wishes in this important endeavour.