TABLE OF CONTENTS
This article explains how the B Lab Standards apply to companies operating across more than one site under a single certification scope. Use it alongside the B Lab Standards and the Certification Scope Requirements to understand how a given sub-requirement is expected to apply across a group's sites.
Two principles underpin how the standards apply across multiple sites:
The central function (see Appendix for the definition) holds the authority and responsibility to define, set up, and maintain the policies, processes, strategies, and other requirements that apply to all operations and sites within the certification scope.
Sites may adapt these central policies or processes to fit their local context. This adaptation must be documented by the site and overseen by the central function, so that local flexibility doesn't come at the expense of group-wide consistency.
Example structures
Example 1: A company has one head office (its central function) and twelve regional offices. The head office sets group-wide policies (for example, code of conduct, grievance procedure) and group targets. Each regional office implements these locally and reports relevant data back to the head office.
Example 2: A retail company has one central function and eighty stores, grouped under five regional hubs. The central function sets policy and strategy; each hub coordinates local implementation and monitoring across its stores and reports consolidated data up to the central function.
How different types of sub-requirements are applied across sites
Based on their specific compliance criteria, sub-requirements in the standards fall into one or more of the following categories:
Governance: highest governing body approval and oversight is required
Communication: internal or external communication is required
Strategy/targets: setting strategies and targets is required
Monitor effectiveness: measuring progress and applying updates is required
Policy: developing policies/processes and implementing them is required
Measure/assess: collecting data or assessment is required
Implement action: the implementation of a specific impact management action is required.
How a sub-requirement applies across multiple sites generally follows the logic of its category, as described in the sections below.
Governance
Governance focused sub-requirements relate to the mandate and oversight responsibilities of the highest governing body (see the definition in the Appendix) within the scope of certification. If the compliance criteria of the sub-requirement calls out specific individuals, like executive team members (see definition in the Appendix), then the sub-requirement applies only to sites where an executive team member is located. Other sites in the scope of the certification, where there are no executive team members, do not need to take any action. For example, it may be that only the central function and a few regional hub sites have a designated executive team member, whereas the other sites do not.
Examples:
PSG5.1: The highest governing body monitors the company's purpose, social and environmental impact, and stakeholder considerations.
Key evidence during the audit will include the highest governing body meeting minutes and governance documents (for instance a record of approval) at central level.
PSG5.3: All members of the executive team have at least one annual target tied to the company’s social or environmental performance.
This applies to the executive team and must cover all executive team members within the scope of certification, regardless of which site they are located in.
JEDI2.d The company’s highest governing body and executive team reflect the diversity of its community.
This sub-requirement applies at the level of the highest governing body and executive team within the certification scope. The sub-requirement covers all members of both groups within the scope of certification.
Communication
Some sub-requirements ask companies to make information publicly available, such as an impact report, emissions disclosures, or policy commitments. The central function (such as a head office) within the scope of certification is responsible for communicating this information publicly and for ensuring that the public disclosure covers the entire certification scope. No separate site-level disclosure is required, unless the sub-requirement specifies it.
Examples:
PSG6.1: The company reports its social and environmental performance annually and publicly, with approval from the highest governing body.
The report is approved by the highest governing body within the certification scope, and covers all sites within the certification scope.
During the audit, individual sites may be asked to demonstrate awareness of the report and, where applicable, how they contributed data.
GACA3.2: The company publicly shares its country-by-country reporting each fiscal year.
The country-by-country report is approved and overseen by the highest governing body within the certification scope, and covers all sites within the certification scope.
During the audit, individual sites may be asked to demonstrate awareness of the report and, where applicable, how they contributed data.
Strategy and Targets
Strategy and target-setting sub-requirements are approved by the highest governing body and governed by the central function, covering the entire certification scope. Sites are expected to implement the group strategy for their local context through roll-out, enforcement, and accountability mechanisms that support the group strategy.
Example:
ESC2.1: The company has a strategy to address its actual and potential negative environmental impacts.
The environmental strategy for the group is approved by the highest governing body and governed by the central function.
Sites implement the group strategy for their local context, for example through adopting the group's energy reduction target and tracking site-level energy consumption against it.
Some elements of the strategy may not be relevant to every site, and for certain sites no elements may apply operationally. In these cases, the central function records a rationale for excluding such sites, as the auditor may request this information.
Monitor Effectiveness
Sub-requirements that monitor effectiveness require the central function to oversee overall progress against the defined strategy and targets. Sites contribute by tracking local indicators and reporting their results to the central function, which reviews progress across all sites within the certification scope. The central function is responsible for the collecting, tracking and monitoring of all required information to provide accurate and transparent reporting of progress from all sites within the certification scope.
Example:
CA3.4: The company makes progress on its climate transition plan and evaluates its effectiveness.
The central function monitors progress against the climate transition plan.
Individual sites contribute by tracking local progress indicators (such as emissions reductions) and reporting their results to the group monitoring process. .
Policy/Procedure
Policy and procedure type sub-requirements are governed by the central function, which is responsible for implementation across all sites. Some sites may have localised adaptations to the central policy or procedure. In these cases, the central function defines which aspects of the policy or procedure are mandatory for all sites and which may be adapted locally.
Examples:
PSG4.2: The company has a responsible marketing and public relations policy overseen by the executive team or highest governing body.
While the policy is developed, approved and overseen by the central function, the implementation applies to all sites and relevant teams (e.g. Marketing, Communications, General Secretary, Public Affairs) within the scope of certification.
The central function is responsible for local adoption and enforcement of the policy or procedure. If a site deviates from the global policy, the central function clarifies why this adaptation is allowed and how consistency across all sites is ensured. For instance, a group marketing and public relations policy may indicate mandatory brand and messaging guidelines, with flexibility for local language and cultural context. Sites should prepare to explain during the audit how they apply the policy in their local marketing activities, including any documented local adaptations. This may include a site in a specific region showing how it has adjusted campaign language or imagery to suit local cultural norms, while still following the mandatory group guidelines.
PSG3.3: The company has a publicly accessible grievance procedure allowing stakeholders to safely raise grievances and seek resolutions.
While the procedure is developed by the central function, it must be implemented by all of the sites within the certification scope to ensure it is accessible to all the stakeholders at each site. Any site-level tracking data may be checked during the audit. For example, records of complaints and evidence that the grievance policy has been applied.
ESC2.6 The company assesses the potential negative environmental impacts related to potential organizational clients and projects, and takes necessary mitigation actions.
The central function is responsible for developing the process and ensuring it is implemented across all sites within the certification scope.
A site may have an adapted version of the client and project assessment procedure to suit its local context as long as consistency across all sites is ensured – the processes should not be fundamentally different. In all cases, sites should be prepared to demonstrate their most material clients, how the assessment process was applied, and how the resulting mitigation actions were carried out.
JEDI2.a The company commits publicly to JEDI principles.
The central function is responsible for developing and overseeing the commitment and ensuring that it applies across all sites within the certification scope.
During the audit, individual sites may be asked to demonstrate awareness of the commitment.
Measure and Assess
Measure and assess sub-requirements are governed by the central function, with data or assessment inputs coming from sites within the certification scope. There are two main variants:
Data-based sub-requirements: These include sub-requirements that ask for data such as greenhouse gas (GHG) emissions, material inflow, or worker compensation data. The data across all sites is compiled and owned by the central function. A data collection process must be in place at each site that enables the effective reporting to the central function. If a site is excluded from the data collection, this must be justified and documented – for example, a site may be excluded from material inflow data collection (ESC3.1) because it is not involved in procurement of materials for the company's products or packaging.
Assessment-based sub-requirements: These cover materiality assessments, including human rights and environmental impact assessments. These must cover all sites within the certification scope and be overseen by the central function. Sites are expected to be aware of the topics identified as material in the materiality assessment and how they are relevant at the site level. If a site conducts its own materiality assessment, this must be clearly documented, explained, and submitted as evidence when requested by the auditor. The central function must maintain oversight of any site-specific policies and processes.
Examples:
CA1.1: The company has a documented process to measure its scope 1, 2 and 3 greenhouse gas emissions annually and discloses the results publicly.
The GHG emissions inventory is compiled from all data sources in each site within the certification scope. This inventory is overseen by the central function. To contribute to the consolidated data, a process for data collection is in place at each site.
PSG2.3: The company conducts a regular materiality assessment to assess and identify material topics.
While the materiality assessment is owned and overseen by the central function, auditors might check if sites selected for audit are aware of the material topics and how they are relevant at the site level.
JEDI2.e: The company carries out an equity audit.
The equity audit is owned and overseen by the central function and the central function ensures that the equity audit represents all operations in scope.
Implement Action
Sub-requirements that need companies to implement some type of action vary most in how they apply across sites. This is because the relevant action may be taken by the central function, by individual sites, or both — depending on the context and nature of the sub-requirement.
Examples include:
JEDI2.4 - JEDI2.6: The company chooses its JEDI actions using data and stakeholder feedback, records them in a plan, and implements them.
The JEDI actions apply to all sites within the certification scope. To the extent possible, actions should be chosen and implemented centrally by the central function and applied uniformly across sites. If the central function decides that specific sites should select different actions than the ones implemented centrally, then they should provide an explanation as to why.
The central function maintains an overview of all chosen actions and is responsible for ensuring the required number of actions is met across all sites within the certification scope. The sites are responsible for reporting back to the central function about their actions and progress against them.
JEDI2.b: The company improves JEDI knowledge and capacity among leaders
The company needs to apply this sub-requirement to at least two of the following groups: the highest governing body, the executive team, human resources staff, training and development staff, or managers.
If the company chooses to improve JEDI knowledge among the highest governing body or the executive team, the sub-requirement applies at the level of the highest governing body and highest executive team within the certification scope.
Ifthe company chooses to improve JEDI knowledge among managers, training and development or human resources staff, the sub-requirement must be applied to all applicable staff and operations at all sites within the certification scope.
JEDI2.f: The company supports at least two employee resource or affinity groups. Each group is associated with a different social identity.
The sub-requirement applies to all sites for which this option is chosen. The affinity groups may be organized at any level: global, regional, by country, or by site. The company decides if the affinity groups have the same or different social identities across sites.
JEDI2.r: The company redesigns a product or service to be more inclusive.
The actions are consolidated and overseen by the central function. Product development decisions may be made centrally or locally. Sites are responsible for recording local implementation where relevant.
GACA2.3: The company takes part in collective action to advance social or environmental impacts.
The collective action may be conducted by the central function or by individual sites. The central function ensures the certifying company as a whole (whether it is taken by the central function or by a site) takes part in the required number of actions.
ESC5.3: The company works with suppliers to prevent or mitigate their most material environmental impacts.
While the central function oversees supplier identification and prioritization, individual sites may execute the engagement with suppliers, depending on who owns the supplier relationship.
Sites selected for audit should be prepared to explain whether any of their own suppliers were among those the central function prioritized, and to provide an overview of the suppliers they are responsible for and the engagement activities they undertake (where applicable).
Appendix
Definitions
Highest governing body: The person or group of people who have ultimate accountability for the whole company. Every organizational entity has one highest governing body, even if it is not explicitly established. A highest governing body can be explicitly established in a number of formats, such as:
a board of directors
a supervisory board
a sole director
joint and several directors
trustees.
For larger companies, a board subcommittee may be considered the highest governing body — as long as the full board is regularly updated on progress and performance.
Executive team: People with delegated authority from the highest governing body to implement strategies and policies that fulfill the company's purpose.
Central function: The identified central function (e.g., site, office, department or role) of a company that holds responsibility for implementing and maintaining the company’s sustainability management system, conducting internal audits, and for ensuring the B Lab Standards requirements are met at the sites within the scope of certification.
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