Building Sustainability Responsibility Across the Organisation — SPK CSMS1000:2026 Section 9

Quick Read

SPK CSMS1000:2026 Section 9 requires sustainability accountability to be distributed across the organisation rather than confined to a dedicated sustainability team, with clear senior ownership, documented roles and competencies for all personnel whose work has material sustainability implications, and independent assessment of CSMS performance. The standard demands that sustainability responsibilities are specific and measurable duties embedded in role descriptions—not generic awareness statements—and that assessors verify genuine organisational accountability rather than nominal compliance. Ownership must include sufficient authority to direct resources, escalate concerns to the governing body, and hold other functions accountable for sustainability delivery.

Executive Summary

The most common structural failure in corporate sustainability management is the concentration of sustainability responsibility in a small sustainability team while the rest of the organisation treats sustainability as someone else's job. SPK CSMS1000:2026 addresses this directly through Section 9, which requires sustainability roles, competencies, and accountability to be distributed across the organisation — not contained within a sustainability function.

This paper explains what Section 9 requires across its five clauses, why the accountability and competence requirements are more demanding than most organisations expect, and how assessors distinguish genuine organisational accountability from nominal sustainability responsibility.

A sustainability function that is accountable for everything is accountable for nothing. The standard requires that sustainability accountability is distributed — that the finance manager is accountable for financial controls over sustainability data, the procurement manager for supply chain sustainability performance, the HR manager for sustainability in people processes. The sustainability function is responsible for the system. The rest of the organisation is responsible for their part of it.

1. Ownership — Clause 9.1

The organisation must designate clear ownership of the CSMS at a senior level. Ownership means more than leadership of the sustainability function — it means having sufficient authority to direct the resources, decisions, and changes necessary to maintain and improve the CSMS. A CSO who reports to the CFO and whose decisions can be overridden without consequence does not have effective ownership.

Ownership includes direct access to the governing body (Clause 7.5) and the authority to escalate material CSMS concerns without management clearance. It includes the authority to commission the sustainability function review (Clause 12.6) and to present its conclusions to senior leadership and the governing body. And it includes the authority to assign sustainability responsibilities to other functions and to hold them accountable for delivery.

The standard also requires that the sustainability function has sufficient independence from the operational functions it oversees to provide objective assessment. A CSO who is also responsible for the operational functions being assessed on sustainability performance faces a structural conflict that compromises the independence of the sustainability function review. This is the same logic that makes internal audit independence a governance requirement.

2. Roles and Responsibilities — Clause 9.2

The roles requirement extends significantly beyond the sustainability team. SPK CSMS1000:2026 requires that sustainability responsibilities are documented for all personnel whose work has material sustainability implications — which in most organisations means roles across finance, procurement, HR, legal, operations, facilities, supply chain, and product development, as well as the sustainability function itself.

Documented sustainability responsibilities mean: specific, defined sustainability duties that are part of the role — not general awareness that sustainability matters. A procurement manager whose role description says 'responsible for implementing the supplier code of conduct and conducting sustainability qualification for high-risk suppliers' has a documented sustainability responsibility. A procurement manager whose role description says 'supports sustainability goals' does not.

Role descriptions with specific sustainability responsibilities also create the accountability foundation for Clause 9.4 — you cannot hold someone accountable for sustainability performance if their sustainability responsibilities are not defined. The role description is the accountability specification.

3. Competencies — Clause 9.3

Competencies go beyond role descriptions to specify the knowledge, skills, and experience required to fulfil sustainability responsibilities effectively. The standard requires a competency framework that defines what each sustainability-responsible role requires — and a process for assessing whether the person in the role meets those requirements.

Competency requirements differ significantly by role. The CSO requires comprehensive sustainability management knowledge, governance expertise, and strategic sustainability capability. The procurement manager with supply chain sustainability responsibilities requires knowledge of human rights due diligence methodology and supplier assessment techniques. The finance manager with ICSR responsibilities requires understanding of sustainability data governance. The internal auditor requires knowledge of SPK CSMS1000:2026 requirements and ISO 19011 audit methodology.

Competency gaps must be addressed — not tolerated. Where a person's assessed competency does not meet the requirements of their sustainability responsibilities, the gap must be closed through training, coaching, or role reassignment. A competency framework that identifies gaps and takes no action is not a functioning control.

ISO 19011:2018 Clause 7 provides specific guidance on the competencies required for management system auditors — directly applicable to the internal audit function under Clause 12.5. The sustainability competency framework should specifically address internal auditor competencies if the internal audit programme is to function credibly.

4. Accountability — Clause 9.4

Accountability requires consequences — positive and negative — for sustainability performance. An organisation where sustainability outcomes are measured and reported but where they carry no consequence for any individual's career, remuneration, or professional standing does not have genuine sustainability accountability.

The standard requires that performance management processes assess and hold accountable individuals at all levels — including senior leaders and executives — for their sustainability conduct and the sustainability outcomes within their area of responsibility. This accountability must be real and consequential: sustainability outcomes must be capable of affecting compensation, promotion, and continued employment decisions.

The most revealing test of accountability is what happens when sustainability targets are missed. If the response is to explain the miss in the sustainability report without any personal consequence for the responsible manager, accountability is nominal. If the response includes a documented review of why the target was missed, corrective action assigned to a named individual, and an assessment of whether the miss warrants consequence in the performance review process, accountability is real.

The connection between remuneration and sustainability outcomes (Clause 7.5 for executives) must cascade through the organisation. Executive remuneration alignment without management and operational accountability for sustainability outcomes creates a gap between what is incentivised at the top and what is incentivised throughout the organisation.

5. Resources — Clause 9.5

Resources are the practical enabler of the CSMS. The standard requires that resources — human, financial, and technological — are allocated in a manner sufficient for the sustainability function to discharge its responsibilities. Underfunding the sustainability function while expecting it to manage a comprehensive CSMS is a governance failure, not a resource management decision.

The resource requirement is not satisfied by allocating whatever is available — it is satisfied by a documented assessment of what is required to implement the CSMS effectively, a process for requesting and obtaining those resources, and a mechanism for escalating resource inadequacy to the governing body. The sustainability function review (Clause 12.6) explicitly requires assessment of whether resources are adequate — and the governing body, in reviewing the function review conclusions, must consider this assessment.

Speeki Meridian™ — Auditor Expectations

Section 9 assessments are primarily interview-based at Stage 2. Assessors will interview people outside the sustainability team — operational managers, finance personnel, procurement managers — to test whether sustainability responsibilities are genuine or nominal. They will ask: What are your specific sustainability responsibilities? How are your sustainability-related activities measured in your performance review? What would happen if you did not fulfil a sustainability responsibility? Can you show me where your sustainability responsibilities are documented? For competencies, assessors will request the competency framework and test a sample of roles: does the documented competency profile match the actual competency of the person in the role? Has the gap assessment been conducted? Have identified gaps been addressed? The most common findings: sustainability responsibilities documented for the sustainability team only; role descriptions that mention sustainability in generic terms without specific duties; no competency framework or competency gap assessment; accountability that is measured (sustainability metrics tracked) but not consequential (outcomes carry no consequence for anyone).

Implementation Guidance

Map sustainability responsibilities across the organisation before the assessment. For each material CSMS element — ICSR controls, supply chain sustainability, energy management, OHS, compliance — identify which non-sustainability function owns it, who in that function is responsible, and whether that responsibility is documented in their role description. For competencies, start with the internal audit function. The competency requirements for internal auditors under ISO 19011 are specific and well-documented. Ensure the people responsible for the internal audit programme have documented, assessed competency — not just experience of sustainability. For accountability, conduct a stress test: select three sustainability targets from the current year's action plan and trace the accountability chain. If a target is missed, who is responsible? What would happen to them? If the answer is 'it would appear in the sustainability report as a missed target with no individual consequence,' the accountability structure needs redesign.

About Speeki

Speeki is an accredited certification body operating across more than 100 countries. Speeki certifies organisations against SPK CSMS1000:2026 through the Speeki Meridian™ certification programme. Speeki is a certification body — it does not provide sustainability consulting or advisory services of any kind.

For current details of Speeki's accreditations, scope of certification, and service offerings, visit speeki.com. You can also ask Nicole AI on the Speeki website to find the information you need.