CSRD
Corporate Sustainability Reporting Directive datapoints
The Corporate Sustainability Reporting Directive replaced the NFRD and pulled thousands of European companies into mandatory sustainability reporting, against the ESRS standards. For a fund, the question is rarely whether the CSRD applies to the fund — it is which portfolio companies fall into which wave, and what they have to be able to produce by then.
This dataset is the ESRS datapoints structured for collection rather than for reading the standard: what to ask a company, not what the regulation says.
Question index
ESRS 2 General Disclosures
- Has the company deviated from the standard medium- or long-term time horizons defined by ESRS 1? If so, specify your definitions and the reasons for applying them.
- If metrics include upstream and/or downstream value chain data estimated using indirect sources (e.g., sector averages or proxies), identify the metrics, describe the preparation basis, accuracy level, and any planned improvements.
- Identify any disclosed quantitative metrics or monetary amounts subject to high measurement uncertainty, specifying the sources of uncertainty and the assumptions, approximations, or judgments applied.
- If disclosing forward-looking information, indicate whether it is considered uncertain.
- If sustainability information preparation or presentation has changed from previous reporting periods, explain the changes, their reasons, disclose revised comparative figures (if possible), and indicate differences from prior figures.
- If material prior period errors are identified, disclose the nature of the error, corrections made (if practicable), or explain why correction is not possible.
- If the sustainability statement includes information from other legislation or reporting standards beyond ESRS, disclose this and specify any partial application with precise references.
- If incorporating information by reference, provide a list of the ESRS disclosure requirements or specific datapoints referenced.
- Provide the number of executive in the administrative, management, and supervisory bodies.
- Provide the number of non-executive members in the administrative, management, and supervisory bodies.
- Provide details on employee and worker representation, as well as members' experience relevant to the company's sectors, products, and geographic locations.
- Provide the percentage of administrative, management, and supervisory body members by gender and other relevant diversity aspects.
- Provide the board's gender diversity ratio as the average ratio of female to male board members.
- Percentage of independent board members
- Describe the roles and responsibilities of administrative, management, and supervisory bodies regarding impacts, risks, and opportunities, including oversight structure, delegation, reporting lines, and target-setting processes.
- Describe how administrative, management, and supervisory bodies ensure they have or develop the necessary sustainability expertise, including access to experts or training, and its relevance to material impacts, risks, and opportunities.
- Describe the significant groups of products and/or services offered, as well as the key markets and/or customer groups served.
- Provide the total number of employees (headcount).
- Provide number of employees at the reporting date (headcount).
- Provide a description of any products and services that are banned in certain markets.
- Provide the total revenue as reported in the financial statements.
- Provide the breakdown of revenue by significant ESRS sectors.
- If the company has used an EU Member State exemption to omit revenue breakdown by ESRS sector, disclose the list of significant ESRS sectors for the company.
- Specify if the company is active in the fossil fuel sector (coal, oil, and gas) and provide the associated revenue breakdown.
- Provide revenue generated from activities in the fossil fuel sector (coal, oil, and gas).
- Provide the revenue derived from coal-related activities.
- Provide the revenue derived from oil-related activities.
- Provide the revenue derived from gas-related activities.
- Provide the revenue from Taxonomy-aligned economic activities related to fossil gas.
- Specify if the company is active in chemicals production.
- Provide the revenue generated from chemicals production.
- Specify if the company is active in controversial weapons production or trade.
- Provide the revenue generated from controversial weapons.
- Describe the company’s business model and value chain, including key inputs, outputs, expected benefits, and the main upstream and downstream actors (suppliers, customers, distribution channels, end-users).
- Provide the revenue generated from the cultivation and production of tobacco.
- What are the sustainability goals related to significant products, services, customer categories, geographical areas, and stakeholder relationships, and how do the current products, services, markets, and customer groups align with these goals? What key elements of the strategy impact sustainability matters? What are the company’s ESRS sectors and its business model, including inputs, outputs, outcomes, and its position in the value chain?
- Describe the company’s material impacts, risks, and opportunities, their effects on the business model and strategy, financial implications, resilience, expected changes over time, and whether disclosures follow ESRS or entity-specific requirements.
- If disclosing material impacts, risks, and opportunities within topical ESRS sections, ensure a statement summarizing them is also presented under this chapter of ESRS 2.
- Provide a list of the Disclosure Requirements covered in the sustainability statement, including page numbers or paragraph references, and a table indicating the location of EU-mandated datapoints, specifying “Not material” where applicable.
- If climate change is deemed not material and ESRS E1 disclosures are omitted, provide a detailed explanation of the materiality assessment conclusions, including a forward-looking analysis of conditions that may make climate change material in the future.
- If a topic other than climate change is deemed not material and its corresponding ESRS disclosures are omitted, a brief explanation of the materiality assessment conclusions may be provided.
- Explain how the company determined the material information to disclose regarding assessed material impacts, risks, and opportunities, including the use of thresholds and application of ESRS 1 section 3.2 criteria.
ESRS E1 Climate Change
- Are climate-related considerations included in the remuneration of administrative, management, and supervisory bodies, and if so, how?
- What percentage of recognised remuneration is linked to climate-related considerations?
- What climate-related considerations are factored into the remuneration of administrative, management, and supervisory bodies?
- How are the company’s targets compatible with limiting global warming to 1.5°C in line with the Paris Agreement? What are the key decarbonization levers and actions, and what significant operational or capital expenditures are needed to implement the action plan?
- What financial resources (OpEx) are allocated to the action plan?
- What financial resources (CapEx) are allocated to the action plan?
- What potential locked-in GHG emissions exist from key assets and products, and how might they jeopardize GHG reduction targets and drive transition risk? Are there any objectives or plans (CapEx, CapEx plans, OpEx) to align economic activities (revenues, CapEx, OpEx) with the criteria established in Commission Delegated Regulation 2021/2139?
- What is the amount of significant CapEx allocated to coal-related economic activities?
- What is the amount of significant CapEx allocated to oil-related economic activities?
- What is the amount of significant CapEx allocated to gas-related economic activities?
- Is the company excluded from EU Paris-aligned Benchmarks? How is the transition plan embedded in and aligned with the overall business strategy and financial planning? Is the transition plan approved by administrative, management, and supervisory bodies, and what progress has been made in its implementation?
- If no transition plan is in place, when will one be adopted?
- For each material climate-related risk, is it considered a physical risk or a transition risk?
- How resilient is the company’s strategy and business model to climate change, including the scope, methodology, timing, and results of resilience and scenario analysis?
- How resilient is the company’s strategy and business model to climate change, including the scope, methodology, timing, and results of resilience and scenario analysis?
- How does the company identify and assess climate-related impacts, risks, and opportunities, including GHG emissions, physical risks, and transition risks or opportunities in its operations and value chain?
- How has climate-related scenario analysis, including multiple scenarios, been used to identify and assess physical and transition risks and opportunities over short, medium, and long-term horizons?
- What actions and resources are allocated for climate change mitigation and adaptation, in line with ESRS 2 MDR-A principles?
- What key actions has the company taken and planned for climate change mitigation, including the use of decarbonization levers and nature-based solutions?
- What are the company’s achieved GHG emission reductions?
- What are the company’s expected GHG emission reductions?
- How does the ability to implement actions depend on available resources, and how are significant CapEx and OpEx tied to financial statements, key performance indicators, and CapEx plans under Commission Delegated Regulation (EU) 2021/2178?
- What information is provided to track the effectiveness of climate change mitigation and adaptation policies and actions through targets, as required by ESRS 2 MDR-T?
- Has the company set GHG emissions reduction targets or other targets related to renewable energy, energy efficiency, adaptation, and risk mitigation?
- What are the baseline year, targets, GHG types, Scope 3 categories, decarbonisation levers, and entity-specific denominators used for intensity values?
- What is the absolute value of total greenhouse gas emissions reduction?
- What percentage of total greenhouse gas emissions reduction has been achieved (relative to the emissions of the base year)?
- What is the intensity value of total greenhouse gas emissions reduction?
- What is the absolute value of Scope 1 greenhouse gas emissions reduction?
- What percentage of Scope 1 greenhouse gas emissions reduction has been achieved (relative to the emissions of the base year)?
- What is the intensity value of Scope 1 greenhouse gas emissions reduction?
- What is the absolute value of location-based Scope 2 greenhouse gas emissions reduction?
- What percentage of location-based Scope 2 greenhouse gas emissions reduction has been achieved (relative to the emissions of the base year)?
- What is the intensity value of location-based Scope 2 greenhouse gas emissions reduction?
- What is the absolute value of market-based Scope 2 greenhouse gas emissions reduction?
- What percentage of market-based Scope 2 greenhouse gas emissions reduction has been achieved (relative to the emissions of the base year)?
- What is the intensity value of market-based Scope 2 greenhouse gas emissions reduction?
- What is the absolute value of Scope 3 greenhouse gas emissions reduction?
- What percentage of Scope 3 greenhouse gas emissions reduction has been achieved (relative to the emissions of the base year)?
- What is the intensity value of Scope 3 greenhouse gas emissions reduction?
- How has consistency been ensured between GHG reduction targets and inventory boundaries? What progress was made prior to the current baseline year? How was the baseline value established to be representative? How does a new baseline impact the target and progress tracking? Is the GHG reduction target science-based and aligned with limiting global warming to 1.5°C? What decarbonization levers are expected, and how were climate scenarios considered in their determination?
- What is the total energy consumption related to the company’s own operations?
- What is the total energy consumption from fossil sources?
- What is the total energy consumption from nuclear sources?
- What percentage of total energy consumption comes from nuclear sources?
- What is the total energy consumption from renewable sources?
- What is the fuel consumption from renewable sources?
- What is the consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources?
- What is the consumption of self-generated non-fuel renewable energy?
- What percentage of total energy consumption comes from renewable sources?
ESRS E2 Pollution
- 4o mini
- How do the company’s targets relate to the prevention and control of the following types of pollution: (a) air pollutants and their respective specific loads, (b) emissions to water and their respective specific loads, (c) pollution to soil and its respective specific loads, (d) substances of concern and substances of very high concern?
- When setting pollution-related targets, did the company consider ecological thresholds (e.g., biosphere integrity, stratospheric ozone depletion, atmospheric aerosol loading, soil depletion, ocean acidification) and entity-specific allocations? If so, please specify: (a) the ecological thresholds identified and the methodology used to determine them, (b) whether the thresholds are entity-specific and, if so, how they were determined, (c) how responsibility for respecting the identified ecological thresholds is allocated within the company?
- Are the targets set by the company related to pollution mandatory (required by legislation) or voluntary? Please specify.
- What is the amount of each pollutant listed in Annex II of Regulation (EC) No 166/2006 (European Pollutant Release and Transfer Register - E-PRTR Regulation) emitted to air, water, and soil, excluding greenhouse gas emissions, which are disclosed in accordance with ESRS E1 Climate Change? Please specify the emissions at site level, by type of source, by sector, and by geographical area
- What is the amount of each pollutant listed in Annex II of Regulation (EC) No 166/2006 (European Pollutant Release and Transfer Register - E-PRTR Regulation) emitted to air excluding greenhouse gas emissions, which are disclosed in accordance with ESRS E1 Climate Change?
- What is the amount of each pollutant listed in Annex II of Regulation (EC) No 166/2006 (European Pollutant Release and Transfer Register - E-PRTR Regulation) emitted to water?
- What is the amount of each pollutant listed in Annex II of Regulation (EC) No 166/2006 (European Pollutant Release and Transfer Register - E-PRTR Regulation) emitted to soil?
- What is the amount of microplastics generated and used by the company?
- What is the amount of microplastics generated by the company?
- What is the amount of microplastics used by the company?
- What are the consolidated amounts of pollutants emitted to air, water, and soil, including emissions from facilities over which the company has financial or operational control, and only from facilities where the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded?
- How does the company contextualize its pollution-related disclosures? Please describe: (a) the changes in pollution over time, (b) the measurement methodologies used, and (c) the processes for collecting data for pollution-related accounting and reporting, including the type of data needed and the sources of this information?
- If the company uses a methodology inferior to direct measurement to quantify emissions, what are the reasons for choosing this methodology? If estimates are used, please specify the standard, sectoral study, or sources that form the basis of these estimates, along with the degree of uncertainty and the range of estimates reflecting the measurement uncertainty.
- What is the total amount of substances of concern that are generated or used during production or that are procured? Please provide a breakdown by the main hazard classes of substances of concern.
- What is the total amount of substances of concern that are generated or used during production or that are procured?
- What is the total amount of substances of concern that leave the company’s facilities as emissions, as products, or as part of products or services?
- What is the amount of substances of concern that leave the company’s facilities as emissions, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of concern that leave the company’s facilities as products, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of concern that leave the company’s facilities as part of products, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of concern that leave the company’s facilities as services, and how is this broken down by the main hazard classes of substances of concern?
- What is the total amount of substances of very high concern that are generated or used during production or that are procured, and how is this broken down by the main hazard classes of substances of concern?
- What is the total amount of substances of very high concern that leave the company’s facilities as emissions, as products, or as part of products or services, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of very high concern that leave the company’s facilities as emissions, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of very high concern that leave the company’s facilities as products, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of very high concern that leave the company’s facilities as part of products, and how is this broken down by the main hazard classes of substances of concern?
- What is the amount of substances of very high concern that leave the company’s facilities as services, and how is this broken down by the main hazard classes of substances of concern?
- What are the anticipated financial effects related to pollution-related risks and opportunities? Please include: (a) a quantification of these effects in monetary terms, and if applicable, whether the effects are presented as a single amount or a range?
- What are the anticipated financial effects related to pollution-related risks and opportunities? Please include: (a) a quantification of these effects in monetary terms, or qualitative information if quantification is not feasible without undue cost or effort; (b) a description of the effects considered, the impacts they are related to, and the time horizons in which they are likely to materialise; (c) the critical assumptions used to quantify these anticipated financial effects, including the sources of these assumptions and the level of uncertainty associated with them?
- What percentage of net revenue is made from products and services that are or contain substances of concern?
- What percentage of net revenue is made from products and services that are or contain substances of very high concern?
- What operating expenditures (OpEx) were incurred in conjunction with major incidents and deposits related to pollution?
- What capital expenditures (CapEx) were incurred in conjunction with major incidents and deposits related to pollution?
- What provisions for environmental protection and remediation costs were made related to pollution, such as for rehabilitating contaminated sites or removing environmental contamination?
- What relevant contextual information can the company provide regarding material incidents and deposits where pollution had negative impacts on the environment, and/or is expected to have negative effects on the company’s financial cash flows, financial position, and financial performance? Please describe these impacts for short-, medium-, and long-term time horizons.
ESRS E3 Water and Marine Resources
- What policies does the company have in place to manage its material impacts, risks, and opportunities related to water and marine resources, in accordance with ESRS 2 MDR-P on policies adopted to manage material sustainability matters?
- How do the company’s policies address the following water and marine resources-related matters: (a) water management, including: i. the use and sourcing of water and marine resources in its own operations, ii. water treatment for more sustainable water sourcing, iii. the prevention and abatement of water pollution from its activities; (b) product and service design aimed at addressing water-related issues and preserving marine resources; and (c) commitment to reduce material water consumption in water-risk areas, both in its own operations and along the upstream and downstream value chain?
- How do the company’s policies address the following water and marine resources-related matters: (a) water management, including: i. the use and sourcing of water and marine resources in its own operations, ii. water treatment for more sustainable water sourcing, iii. the prevention and abatement of water pollution from its activities; (b) product and service design aimed at addressing water-related issues and preserving marine resources; and (c) commitment to reduce material water consumption in water-risk areas, both in its own operations and along the upstream and downstream value chain?
- How does the company describe the actions and resources allocated to manage water and marine resources, in accordance with the principles defined in ESRS 2 MDR-A on actions and resources related to material sustainability matters? Additionally, to which layer of the mitigation hierarchy (avoidance, minimisation, restoration, or compensation) do these actions apply?
- How does the company allocate resources to manage water and marine resources, including: (a) avoiding the use of water and marine resources, (b) reducing the use of water and marine resources through efficiency measures, (c) reclaiming and reusing water, or (d) restoring and regenerating aquatic ecosystems and water bodies?
- What actions and resources has the company allocated in relation to areas at water risk, including areas of high-water stress?
- How does the company track the effectiveness of its policies and actions related to water and marine resources through defined targets, in accordance with the requirements set out in ESRS 2 MDR-T?
- How do the company’s targets relate to the following areas: (a) the management of material impacts, risks, and opportunities related to areas at water risk, including improvement of water quality, (b) the responsible management of marine resources, including the nature and quantity of marine resources-related commodities (such as gravels, deep-sea minerals, seafood) used by the company, (c) the reduction of water consumption, and how are these targets connected to areas at water risk, including areas of high water stress?
- When setting targets related to water and marine resources, did the company consider ecological thresholds and entity-specific allocations? If so, please specify: (a) the ecological thresholds identified and the methodology used to determine them, (b) whether the thresholds are entity-specific and, if so, how they were determined, (c) how responsibility for respecting the identified ecological thresholds is allocated within the company?
- Are the targets set by the company related to water and marine resources mandatory (required by legislation) or voluntary? Please specify.
- What is the total water consumption in cubic meters (m3) for the company’s own operations?
- What is the total water consumption in cubic meters (m3) in areas at water risk, including areas of high-water stress?
- What is the total amount of water recycled and reused in cubic meters (m3) by the company?
- What is the total amount of water stored, measured in cubic meters (m3)?
- What are the changes in storage, measured in cubic meters (m3)?
- What contextual information is necessary to understand the total water consumption, recycling, reuse, and storage, including information on the water basins’ quality and quantity, the standards, methodologies, and assumptions used and whether the data is calculated, estimated, modelled, or sourced from direct measurements ?
- What is the share of the water data obtained from direct measurement, sampling and extrapolation, or best estimates?
- What is the company’s water intensity, defined as total water consumption in cubic meters (m3) per million EUR of net revenue?
- What are the anticipated financial effects related to water and marine resources risks and opportunities? Please include: (a) a quantification of these effects in monetary terms, and if applicable, whether the effects are presented as a single amount or a range
- What are the anticipated financial effects related to water and marine resources risks and opportunities? Please include: (a) a quantification of these effects in monetary terms, or qualitative information if quantification is not possible without undue cost or effort ; (b) a description of the effects considered, the impacts and dependencies they relate to, and the time horizons in which they are likely to materialise; (c) the critical assumptions used to quantify the anticipated financial effects, including the sources of these assumptions and the level of uncertainty associated with them?
ESRS E4 Biodiversity and Ecosystems
- "How resilient is the company's strategy and business model to biodiversity and ecosystem-related physical, transition, and systemic risks? Please include the following information: (a) the assessment of resilience to these risks, (b) the scope of the analysis for the company’s own operations and its upstream and downstream value chain, (c) the key assumptions made, (d) the time horizons used, (e) the results of the resilience analysis, (f) the involvement of stakeholders, including, where appropriate, holders of indigenous and local knowledge."
- If the company has disclosed information related to biodiversity and ecosystems resilience as part of the information required under ESRS 2 SBM-3, can it refer to or incorporate that information here?
- Has the company disclosed its transition plan to improve and align its business model and strategy with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, and the planetary boundaries related to biosphere integrity and land system change? If so, please describe the plan and its objectives.
- How does the company identify and assess material impacts, risks, dependencies, and opportunities related to biodiversity and ecosystems? Please include: (a) the identification and assessment of actual and potential impacts on biodiversity and ecosystems at company sites and in the upstream and downstream value chain, including the assessment criteria applied; (b) the identification and assessment of dependencies on biodiversity and ecosystems and their services, including any disrupted or likely disrupted ecosystem services; (c) the identification and assessment of transition and physical risks and opportunities related to biodiversity and ecosystems, with the criteria applied; (d) the consideration of systemic risks; (e) whether and how the company consulted with affected communities on sustainability assessments of shared biological resources and ecosystems, including: i. identifying specific sites or raw material production/sourcing likely to negatively impact biodiversity and ecosystems, ii. how affected communities were involved in the materiality assessment, iii. how the company plans to avoid or minimise negative impacts on ecosystem services, and if unavoidable, how it intends to implement mitigation measures to maintain the value and functionality of priority services?
- Has the company used biodiversity and ecosystems scenario analysis to identify and assess material risks and opportunities over short-, medium-, and long-term time horizons? If so, please describe: (a) why the selected scenarios were chosen, (b) how the scenarios are updated according to evolving conditions and emerging trends, (c) whether the scenarios are informed by expectations published by authoritative intergovernmental bodies, such as the Convention for Biological Diversity, and by scientific consensus, such as that expressed by the Intergovernmental Science-policy Platform on Biodiversity and Ecosystem Services (IPBES)?
- Does the company have sites located in or near biodiversity-sensitive areas, and do activities at these sites negatively affect these areas by causing the deterioration of natural habitats, species habitats, or disturbance to protected species? Additionally, has the company concluded that it is necessary to implement biodiversity mitigation measures, such as those identified in EU directives or international standards like the IFC Performance Standard 6?
- What policies does the company have in place to manage its material impacts, risks, dependencies, and opportunities related to biodiversity and ecosystems, in accordance with ESRS 2 MDR-P on policies adopted to manage material sustainability matters?
- How do the company’s biodiversity and ecosystems-related policies address the following: (a) the matters specified in ESRS E4 AR 4, (b) material biodiversity and ecosystems-related impacts, (c) material dependencies, physical and transition risks, and opportunities, (d) traceability of products, components, and raw materials with material impacts on biodiversity and ecosystems along the value chain, (e) production, sourcing, or consumption from ecosystems managed to maintain or enhance biodiversity, as demonstrated by regular monitoring and reporting of biodiversity status, gains, or losses, (f) the social consequences of biodiversity and ecosystems-related impacts?
- Has the company adopted policies related to biodiversity and ecosystems, including: (a) a biodiversity and ecosystem protection policy covering operational sites in or near biodiversity-sensitive areas, (b) sustainable land or agricultural practices or policies, (c) sustainable oceans or seas practices or policies, (d) policies to address deforestation?
- How does the company describe the key actions and resources allocated to manage biodiversity and ecosystems, in accordance with the mandatory content defined in ESRS 2 MDR-A on actions and resources related to material sustainability matters?
- How has the company applied the mitigation hierarchy in its biodiversity and ecosystems-related actions (avoidance, minimisation, restoration/rehabilitation, and compensation or offsets)? Additionally, if biodiversity offsets are used, please provide the following details: (a) the aim of the offset and the key performance indicators used, (c) a description of the offsets, including the area, type, quality criteria applied, and standards they comply with. Finally, has the company incorporated local and indigenous knowledge and nature-based solutions into its biodiversity and ecosystems-related actions?
- If biodiversity offsets are used, please provide the following details: (b) the financing effects (direct and indirect costs) of biodiversity offsets in monetary terms,
- How does the company track the effectiveness of its biodiversity and ecosystems-related policies and actions through defined targets, in accordance with the mandatory content defined in ESRS 2 MDR-T?
- When setting biodiversity and ecosystems-related targets, did the company apply ecological thresholds and allocations of impacts? If so, please provide the following details: (a) the ecological thresholds identified and the methodology used to determine them, (b) whether the thresholds are entity-specific and how they were determined, (c) how responsibility for respecting identified ecological thresholds is allocated within the company; Additionally, are the targets informed by or aligned with the Kunming-Montreal Global Biodiversity Framework, the EU Biodiversity Strategy for 2030, or other relevant national policies and legislation? Please also describe: (d) how the targets relate to the biodiversity and ecosystem impacts, dependencies, risks, and opportunities identified by the company in relation to its operations and value chain, (e) the geographical scope of the targets (if relevant), (f) whether biodiversity offsets were used in setting the targets, and (g) to which layers of the mitigation hierarchy (avoidance, minimisation, restoration/rehabilitation, compensation/offsets) the targets apply?
- If the company has identified sites located in or near biodiversity-sensitive areas that it is negatively affecting, what is the number of these sites that are owned, leased, or managed by the company?
- If the company has identified sites located in or near biodiversity-sensitive areas that it is negatively affecting, what is the area (in hectares) of these sites that are owned, leased, or managed by the company?
- If the company has identified material impacts related to land-use change or the extent and condition of ecosystems, has it disclosed its land-use based on a Life Cycle Assessment?
- For the datapoints specified in paragraphs 38 to 41, has the company considered its own operations in the disclosures
- If the company has concluded that it directly contributes to land-use change, freshwater-use change, and/or sea-use change, what relevant metrics has it reported? Please include metrics that measure: (a) the conversion over time (e.g., 1 or 5 years) of land cover (e.g., deforestation or mining), (b) changes in the management of the ecosystem over time (e.g., agricultural intensification, better management practices, or forestry harvesting), (c) changes in the spatial configuration of the landscape (e.g., habitat fragmentation or changes in ecosystem connectivity), (d) changes in ecosystem structural connectivity (e.g., habitat permeability and arrangements of habitat patches), and (e) changes in functional connectivity (e.g., how genes or individuals move through land, freshwater, and seascapes)?
- If the company has concluded that it directly contributes to the introduction of invasive alien species, whether accidental or voluntary, what metrics does it use to manage the pathways of introduction and spread, and how does it address the risks posed by these species?
- If the company has identified material impacts related to the state of species, what relevant metrics does it report? Please include: (a) any references to relevant disclosure requirements in ESRS E1, ESRS E2, ESRS E3, and ESRS E5; (b) metrics related to population size, range within specific ecosystems, and extinction risk, to provide insight into species' health and resilience; (c) metrics that measure changes in the number of individuals of a species within a specific area; (d) metrics on species at extinction risk, including: i. the threat status of species and how company activities or pressures may affect that status, or ii. changes in relevant habitat for a threatened species as a proxy for the company’s impact on the local population’s extinction risk?
- If the company has identified material impacts related to ecosystems, what relevant metrics does it disclose? Please include: (a) metrics measuring the area coverage of a particular ecosystem (e.g., habitat cover), without considering the quality of the area; (b) metrics measuring the condition of ecosystems, including: i. quality relative to a pre-determined reference state, ii. metrics that measure multiple species within an ecosystem, such as species richness and abundance indicators compared to the reference state and the targeted state outlined in the Kunming-Montreal Global Biodiversity Framework, or iii. metrics reflecting structural components of ecosystem condition, such as habitat connectivity (i.e., how linked habitats are to each other)?
- What are the anticipated financial effects related to biodiversity and ecosystem risks and opportunities? Please include: (a) a quantification of these financial effects in monetary terms, and if applicable, whether the effects are presented as a single amount or a range;
- What are the anticipated financial effects related to biodiversity and ecosystem risks and opportunities? Please include: (a) a quantification of these financial effects in qualitative information if quantification is not feasible without undue cost or effort; (b) a description of the effects considered, the impacts and dependencies they relate to, and the time horizons in which they are likely to materialise; (c) the critical assumptions used to quantify these financial effects, including the sources of these assumptions and the level of uncertainty associated with them?
ESRS E5 Resource Use and Circular Economy
- What policies does the company have in place to manage its material impacts, risks, and opportunities related to resource use and circular economy, in accordance with ESRS 2 MDR-P on policies adopted to manage material sustainability matters?
- Do the company's policies address transitioning away from the use of virgin resources, including any relative increases in the use of secondary (recycled) resources? If so, how?" Additionally, do the company's policies address the sustainable sourcing and use of renewable resources? If so, how?
- Do the company's policies address material impacts, risks, and opportunities both in its own operations and along its upstream and downstream value chain? If so, how?
- How does the company describe the actions and resources allocated to manage resource use and circular economy-related matters, in accordance with the principles defined in ESRS 2 MDR-A on actions and resources related to material sustainability matters?
- How does the company address resource use and circular economy practices, including improving resource efficiency (especially in critical raw materials and rare earths), promoting secondary raw materials (recyclates), applying circular design for product durability and optimisation, implementing circular business practices (value retention, maximisation, end-of-life actions, and systems efficiency), preventing waste generation in its value chain, and optimising waste management in line with the waste hierarchy?
- How does the company track the effectiveness of its policies and actions related to resource use and circular economy through defined targets, in accordance with the requirements set out in ESRS 2 MDR-T?
- How do the company’s targets related to resource inflows and outflows, including waste, products, and materials, address the following areas: (a) increase in circular product design (e.g., durability, dismantling, reparability, recyclability); (b) increase in the rate of circular material use; (c) minimisation of primary raw material use; (d) sustainable sourcing and use of renewable resources (in line with the cascading principle); (e) waste management, including preparation for proper treatment; and (f) other matters related to resource use or circular economy?
- To which layer of the waste hierarchy do the company’s targets related to resource use and circular economy specifically apply?
- When setting targets related to resource use and circular economy, did the company consider ecological thresholds and entity-specific allocations? If so, please specify: (a) the ecological thresholds identified and the methodology used to determine them; (b) whether the thresholds are entity-specific and, if so, how they were determined?
- Are the targets set by the company related to resource use and circular economy mandatory (required by legislation) or voluntary? Please specify.
- What are the resource inflows, including materials (such as critical raw materials and rare earths), products (including packaging), water, and property, plant, and equipment used in the company's operations and its upstream value chain?
- What is the total weight (in tonnes or kilograms) of products and technical and biological materials used to manufacture the company’s products and services during the reporting period?
- What percentage of biological materials (and biofuels used for non-energy purposes) used in the company’s products and services (including packaging) is sustainably sourced, and what certification schemes were applied, including the cascading principle?
- What is the weight (in absolute value) of secondary reused or recycled components, secondary intermediary products, and secondary materials used to manufacture the company’s products and services (including packaging)?
- What is the percentage of secondary reused or recycled components, secondary intermediary products, and secondary materials used to manufacture the company’s products and services (including packaging)?
- What methodologies were used to calculate the data on resource inflows, and is the data sourced from direct measurement or estimations? Please disclose the key assumptions used.
- What are the key products and materials from the production process that are designed according to circular principles (durability, reusability, repairability, recycling, etc.)?
- What is the durability, reparability (using an established rating system, if available), and recyclable content rate of the products and packaging placed on the market by the company, compared to the industry average?
- Report the percentage of recyclable materials used in your products.
- Report the percentage of recyclable materials used in your packaging.
- What is the total amount of waste generated by the company?
- How much waste has been diverted from disposal, specifying the amount of hazardous and non-hazardous waste and the treatment methods used, with a breakdown by the following recovery operation types: (i) preparation for reuse, (ii) recycling, and (iii) other recovery operations?
- How much waste has been directed to disposal, specifying the amount by weight for each waste treatment type (i.e., incineration, landfill, and other disposal operations), along with the total amount summing all three types, with a breakdown between hazardous and non-hazardous waste?
- What is the total amount of waste that has not been recycled?
- What percentage of the total waste generated is non-recycled?
- What are the relevant waste streams generated by the company based on its sector or activities, and what materials are present in the waste (e.g., biomass, metals, non-metallic minerals, plastics, textiles, critical raw materials, and rare earths)?
- What is the total amount of hazardous waste generated by the company, with radioactive waste defined as per Article 3(7) of Council Directive 2011/70/Euratom92?
- What is the total amount of radioactive waste generated by the company?
- What methodologies, criteria, and assumptions are used to calculate the data and classify products as designed according to circular principles? Additionally, is the data sourced from direct measurement or estimations, and what key assumptions are disclosed?
- What are the anticipated financial effects related to resource use and circular economy-related risks/opportunities, quantified in monetary terms if possible ?
- What are the anticipated financial effects related to resource use and circular economy-related risks/opportunities described qualitatively, specifying key assumptions and the level of uncertainty?
ESRS S1 Own Workforce
- How does your organization evaluate whether—and how—actual and potential impacts on your workforce (as identified through your ESRS 2 IRO-1 processes) stem from or relate to your strategy and business model, and how do these insights drive adaptations in your strategic framework? Additionally, what is the relationship between the material risks and opportunities arising from these workforce impacts and your overall strategy?
- How does your organization ensure that your ESRS disclosure fully covers all individuals in your workforce—whether employees, self-employed, or third-party workers—who may be materially impacted by your operations, value chain, or business relationships? In your response, please detail: (a) the types of workers affected; (b) whether material negative impacts (such as forced, compulsory, or child labour) are widespread/systemic or incident-specific, and describe any material positive impacts along with the activities driving them; (c) the material risks and opportunities arising from these impacts, including those related to transition plans for environmental sustainability (e.g., carbon reduction measures that may lead to restructuring, job losses, or opportunities for reskilling/upskilling); and (d) any operations or geographic areas identified as being at significant risk of forced, compulsory, or child labour incidents.
- How has your organization, using insights from your ESRS 2 IRO 1 materiality assessment, identified which segments of your workforce—based on specific characteristics, work contexts, or activities—are at greater risk of harm, and how is this understanding integrated into your risk management processes?
- Which material risks and opportunities stemming from workforce impacts and dependencies are specific to certain groups (for example, defined by age, location, or operational role) rather than affecting your entire workforce uniformly, and what targeted strategies does your organization employ to manage these group-specific issues?
- How has your organization established policies in line with ESRS 2 MDR-P to manage the material impacts, risks, and opportunities associated with its workforce, and do these policies apply universally or are they tailored to specific groups?
- How does your organization define and implement its human rights policy commitments for your workforce? Please detail your approach to: (a) respecting human and labour rights; (b) engaging with your workforce; and (c) providing effective remedies for human rights impacts—specifically outlining the processes and mechanisms used to monitor compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.
- How does your organization ensure that its workforce policies are aligned with internationally recognized instruments—such as the UN Guiding Principles on Business and Human Rights—and what formal processes are in place to monitor, review, and update this alignment?
- Do your workforce-related policies explicitly address trafficking in human beings, forced or compulsory labour, and child labour? If so, what specific provisions and enforcement measures are in place to combat these practices?
- Does your organization have a dedicated workplace accident prevention policy or management system? If so, please describe its scope, implementation processes, monitoring mechanisms, and how its effectiveness is evaluated.
- How does your organization ensure that it has specific policies to eliminate discrimination—including harassment—and promote equal opportunities, diversity, and inclusion? In your response, please confirm if your policies explicitly cover discrimination based on factors such as racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction, or social origin (and any other forms as required by applicable Union regulations or national law). Additionally, what targeted commitments do you have for the inclusion or positive action for vulnerable groups, and how are these policies implemented through concrete procedures to prevent, mitigate, and address discrimination?
- How does your organization integrate the perspectives of its workforce into decisions and actions aimed at managing their impacts? In your response, please explain whether engagement occurs directly with employees or via workers' representatives, detail the stages, types, and frequency of such engagement, identify the most senior role responsible for ensuring effective engagement and integration of insights, describe any Global Framework Agreements or similar arrangements with workers' representatives that facilitate respect for human rights, and explain how you assess the effectiveness of this engagement, including any resultant agreements or outcomes.
- What specific measures does your organization take to gain insights into the perspectives of vulnerable or marginalized groups within your workforce (e.g., women, migrants, people with disabilities), and how are these insights captured and integrated into your organizational practices?
- Does your organization currently have a general process to engage with its workforce as required? If not, please confirm that no such process exists and indicate any planned timeframe for its development and implementation.
- How does your organization manage remedy processes for material negative impacts on its workforce? In your response, please explain: (a) your general approach and specific processes for providing remedy, including how you assess their effectiveness; (b) the dedicated channels available for employees to raise concerns—whether established in-house or via third-party mechanisms; (c) whether you have an established grievance/complaints handling mechanism for employee matters; (d) the steps taken to support the accessibility and availability of these channels in the workplace; and (e) how you track, monitor, and evaluate issues raised and resolved, including the involvement of stakeholders to ensure the channels’ effectiveness.
- How does your organization assess whether employees are aware of and trust the established channels for raising concerns, and what methods are used to evaluate their effectiveness? Additionally, do you have formal policies that protect individuals—including workers’ representatives—from retaliation when using these channels, and what do these policies entail?
- Does your organization currently provide an established channel for employees to raise concerns and have them addressed? If not, please confirm that such a channel is not in place and specify any planned timeframe for its implementation.
- How does your organization summarize its action plans and allocated resources for managing material impacts, risks, and opportunities related to its workforce in accordance with ESRS 2 MDR-A, and can you provide a concise description of these strategies?
- How does your organization address material impacts on its workforce? Please describe: (a) the actions taken, planned, or underway to prevent or mitigate negative impacts; (b) how you have provided or enabled remedy in response to actual negative impacts; (c) any additional initiatives designed to deliver positive impacts for your workforce; and (d) the methods used to track and assess the effectiveness of these actions and initiatives.
- How does your organization determine which actions are necessary and appropriate in response to an actual or potential negative impact on its workforce? Please describe the processes you use to assess, prioritize, and decide on the most suitable remedial actions.
- How is your organization addressing material risks and opportunities related to its workforce? Specifically, please describe: (a) the actions planned or underway to mitigate material risks arising from your impacts and dependencies on your workforce, including how you track their effectiveness; and (b) the actions planned or underway to pursue material opportunities concerning your workforce.
- How does your organization ensure that its operational practices—including procurement, sales, and data use—do not cause or contribute to material negative impacts on your workforce? Additionally, when conflicts arise between mitigating these impacts and other business pressures, what strategies or processes do you employ to manage such tensions?
- How does your organization integrate target-setting into its process for tracking the effectiveness of policies and actions addressing material risks and opportunities related to your workforce, as outlined in ESRS 2 MDR-T? Could you provide specific examples of targets used and explain how these targets inform your evaluation of action outcomes?
- What specific resources (financial, human, technological, etc.) has your organization allocated to manage its material impacts, and how is this allocation communicated to stakeholders to clearly demonstrate how these impacts are managed?
- How has your organization established targets to manage material impacts, risks, and opportunities related to its workforce, and can you provide a summarized description of these targets that meets all the information requirements defined in ESRS 2 MDR-T?
- How does your organization establish targets to manage material impacts, risks, and opportunities related to its workforce? In your response, please detail the process, including how you engage directly with your workforce or their representatives in (a) setting these targets, (b) tracking performance against them, and (c) identifying lessons learned or improvements based on your performance.
- What is your organization's total employee headcount? Please include breakdowns by gender and by country (only for countries where you have at least 50 employees representing at least 10% of your total workforce).
- What are the total numbers for your permanent employees, temporary employees, and non‐guaranteed hours employees, reported as either headcount or full-time equivalents (FTE)? Please provide a gender breakdown for each category.
- What is the total number of employees who left during the reporting period, and what is your employee turnover rate for that period?
- In addition, please describe in detail the methodologies and assumptions used to compile these figures (for example, whether figures are reported as headcount or FTE, how FTE is defined, the reporting period employed, and any contextual information necessary to explain fluctuations), and provide a cross‐reference to the most representative number in your financial statements.
- What is the total number of non-employees in your workforce—that is, self-employed individuals or those provided by third-party employment undertakings (NACE Code N78)?
- Please also provide a detailed explanation of the methodologies and assumptions used to compile these figures, including: Whether the numbers are reported as headcount or full-time equivalent (FTE) (with a definition of FTE); The time basis used (e.g., end-of-period, average across the period, or another methodology); and Any contextual information necessary to understand significant fluctuations in these numbers during the reporting period relative to previous periods.
- Where data is unavailable, do you provide an estimate for the missing figures? If so, please explain the basis of preparation for these estimates, including the methodologies, assumptions, and rationale underpinning your estimation process.
- What is the overall percentage of your total employees covered by collective bargaining agreements?
- For each EEA country where you have significant employment (i.e., at least 50 employees representing at least 10% of your total workforce), do you have one or more collective bargaining agreements? If yes, what is the percentage of employees covered by these agreements in that country?
- For regions outside the EEA, what is the percentage of your employees covered by collective bargaining agreements?
- Please describe the data sources and methodologies used to calculate these figures.
- What is the global percentage of your employees covered by workers’ representatives? Please provide a country-level breakdown for each EEA country where you have significant employment (e.g., at least 50 employees representing at least 10% of your total workforce).
- Do you have any agreement with your employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council? If yes, please provide details.
- Does your organization ensure that all employees receive an adequate wage in line with applicable benchmarks? If so, please confirm that this is the case. Does your organization ensure that all employees receive an adequate wage in line with applicable benchmarks? If so, please confirm that this is the case.
- In which countries do some employees earn below the applicable adequate wage benchmark?
- For each of these countries, what percentage of employees earns below the applicable adequate wage benchmark?
- Are all your employees covered by social protection against income loss due to sickness (through public programs or company benefits)?
- Are all your employees covered by social protection against income loss due to unemployment (from the time they start working for your organization)?
- Are all your employees covered by social protection against income loss due to employment injury and acquired disability?
- Are all your employees covered by social protection against income loss due to paternal leave?
- Are all your employees covered by social protection against income loss due to retirement?
- If not all employees are covered by social protection (as specified in paragraph 72), please identify the countries where some employees lack coverage for any major life event (sickness, unemployment, employment injury and acquired disability, paternal leave, or retirement) and specify, for each country, the employee categories without such protection for each applicable event.
- What percentage of your workforce (employees and non‑employees) is covered by your health and safety management system based on legal requirements and/or recognized standards or guidelines?
- What is the total number of fatalities resulting from work‑related injuries and work‑related ill health? Please include data for employees and for other workers (e.g., value chain workers on your sites).
- What is the number and rate of recordable work‑related accidents, disaggregated by employees and non‑employees where applicable?
- For employees, what is the number of cases of recordable work‑related ill health (subject to legal data collection restrictions)?
- For employees, what is the total number of days lost due to work‑related injuries, work‑related accidents, work‑related ill health, and fatalities from ill health?
- What is the percentage of your employees entitled to take family-related leave?
- For employees entitled to family-related leave, what percentage actually took leave, and what is the gender breakdown of those who took leave?
- Do all of your employees have entitlement to family-related leave through social policy and/or collective bargaining agreements?
- What is your organization's gender pay gap, defined as the difference between the average pay levels of female and male employees, expressed as a percentage of the average male pay level?
- What is the annual total remuneration ratio of your highest paid individual to the median annual total remuneration of all employees (excluding the highest paid individual)?
- Please provide any contextual information necessary to understand these figures, including details on how the data was compiled and any changes to the underlying data.
- What work-related incidents of discrimination—including harassment—occurred during the reporting period? For each incident, please specify the grounds for discrimination (e.g., gender, racial/ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant factors) and indicate whether the incident involved internal or external stakeholders, ensuring compliance with relevant privacy regulations.
- What is the total number of discrimination incidents, including harassment, reported during the reporting period?
- What is the number of complaints filed through your internal channels (including grievance mechanisms and, where applicable, National Contact Points for OECD Multinational Enterprises) related to the matters defined in paragraph 2, excluding those already reported as incidents?
- What is the total amount of fines, penalties, and compensation for damages resulting from the reported incidents and complaints, and how does this amount reconcile with the most relevant figure presented in your financial statements?
- Please provide any contextual information necessary to understand the above data, including details on how the data was compiled and any relevant methodological notes.
- What is the total number of severe human rights incidents (e.g., forced labour, human trafficking, or child labour) connected to your workforce during the reporting period? Additionally, how many of these incidents involve non‑respect of the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises? (If no such incidents occurred, please state this.)
- What is the total amount of fines, penalties, and compensation for damages related to these severe human rights incidents, and how does this monetary amount reconcile with the corresponding figure in your financial statements?
ESRS S2 Workers in the Value Chain
- How do actual and potential impacts on value chain workers—identified through your ESRS 2 IRO-1 processes—originate from or connect to your strategy and business model, and how do they inform adaptations to it? Additionally, please describe the relationship between material risks and opportunities arising from impacts and dependencies on value chain workers and your overall strategy and business model.
- How do you ensure that all value chain workers likely to be materially impacted by your operations, products/services, or business relationships are included in your disclosure? Please describe: The types of value chain workers potentially impacted (for example, on-site non-employees, upstream workers, downstream workers, joint venture workers, and those particularly vulnerable such as trade unionists, migrant workers, home workers, women, or young workers); Any specific geographies, country levels, or commodities where there is a significant risk of child labour or forced/compulsory labour; Whether material negative impacts on these workers are widespread/systemic or linked to individual incidents (including impacts arising from the transition to greener, climate-neutral operations); Any material positive impacts, including the activities that generate these benefits and the types of workers positively affected; and The material risks and opportunities arising from impacts and dependencies on value chain workers.
- How has your organization developed an understanding of the increased risks facing specific groups of value chain workers—based on their characteristics, work contexts, or activities—and how does this inform your risk management strategies? How have you developed an understanding—based on your ESRS 2 IRO-1 materiality assessment—of how value chain workers with specific characteristics, working in particular contexts, or engaged in certain activities may be at greater risk of harm?
- What material risks and opportunities arising from impacts and dependencies on your value chain workers are specific to particular groups (e.g., by age, location, or operational role), and how are these group-specific issues managed? for 8 seconds Which material risks and opportunities arising from impacts and dependencies on your value chain workers apply specifically to certain groups (e.g., based on age, location, or operational context) rather than to the entire value chain workforce?
- How does your organization manage material impacts, risks, and opportunities related to value chain workers? Please describe the policies adopted per ESRS 2 MDR-P and indicate whether these policies cover all value chain workers or only specific groups.
- How does your organization’s human rights policy address value chain workers? Please describe your commitments and the processes or mechanisms used to monitor compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. In your response, focus on: Respect for human rights, including labor rights, of value chain workers Engagement with value chain workers Measures to provide and/or enable remedy for human rights impacts
- Does your organization’s policy for value chain workers explicitly address trafficking in human beings, forced or compulsory labour, and child labour, and do you have a supplier code of conduct in place?
- How are your organization’s policies regarding value chain workers aligned with internationally recognized instruments, such as the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises? Additionally, to what extent have cases of non-respect of these principles involving value chain workers been reported in your upstream and downstream value chain, and what is the nature of these cases, if applicable?
- How do the perspectives of value chain workers inform your decisions and actions for managing their actual and potential impacts? In your response, please explain: • Whether engagement occurs directly with value chain workers, their legitimate representatives, or credible proxies; • At what stages, through what types, and how frequently such engagement takes place; • Which function and most senior role is responsible for ensuring this engagement and integrating its outcomes; • Any Global Framework Agreements or similar arrangements with global union federations that help capture these perspectives; and • How you assess the effectiveness of your engagement, including any resulting agreements or outcomes.
- What steps does your organization take to capture and understand the perspectives of workers who may be particularly vulnerable or marginalized (e.g., women, migrant workers, or workers with disabilities)?
- Do you currently have a general process in place to engage with workers in your value chain? If not, please confirm this and specify the timeframe in which you plan to implement such a process.
- How does your organization address material negative impacts on value chain workers? Please describe your overall approach and processes for providing or contributing to remedy, including: • How you assess the effectiveness of the remedy provided; • The channels available for value chain workers to raise concerns or needs (and whether these are established internally or through third-party mechanisms); • The steps you take to ensure these channels are accessible in the workplace; and • How you track, monitor, and evaluate issues raised and addressed, including the involvement of relevant stakeholders.
- How does your organization assess whether value chain workers are aware of and trust the available structures or processes for raising concerns or needs? Additionally, do you have policies in place to protect individuals who use these mechanisms from retaliation? If this information has already been disclosed under ESRS G1-1, please refer to that disclosure.
- Do you have a dedicated channel for value chain workers to raise concerns? If not, please confirm its absence and provide any planned timeframe for its implementation.
- How does your organization address material impacts on value chain workers? Please describe: The actions taken, planned, or underway to prevent or mitigate material negative impacts; Any measures implemented to provide or enable remedy for actual material impacts; Additional initiatives aimed at delivering positive impacts; and How you track and assess the effectiveness of these actions and initiatives.
- How does your organization determine and implement appropriate actions for actual or potential negative impacts on value chain workers? Please explain your process for identifying necessary actions, your approach to responding (e.g., changes in purchasing practices, capacity-building, stakeholder engagement, or collaborative initiatives), and how you ensure that remedy processes are both available and effective.
- How does your organization address material risks and opportunities related to value chain workers? In your response, please describe the actions planned or underway to mitigate material risks (including how you track their effectiveness) and the actions planned or underway to pursue material opportunities.
- How does your organization take action to avoid causing or contributing to material negative impacts on value chain workers through its own practices, particularly in procurement, sales, and data use? Additionally, how do you manage tensions between preventing or mitigating these negative impacts and other business pressures?
- Have any severe human rights issues or incidents connected to your upstream and downstream value chain been reported? If yes, please disclose the details of these incidents.
- If you evaluate the effectiveness of your positive-impact actions for value chain workers by setting targets, how do you track and assess progress against these targets in accordance with ESRS 2 MDR-T requirements?
- What resources does your organization allocate to manage its material impacts, and how do these allocations contribute to effective impact management?
- What targets has your organization set to manage material impacts, risks, and opportunities related to value chain workers, and how do these targets meet the information requirements defined in ESRS 2 MDR-T?
- What is your organization’s process for setting targets related to managing material impacts, risks, and opportunities on value chain workers? In your response, please describe how you engage with value chain workers, their legitimate representatives, or credible proxies during the target-setting phase, tracking performance against these targets, and identifying lessons learned or improvements based on your performance.
ESRS S3 Affected Communities
- How do the actual and potential impacts on affected communities—identified via your ESRS 2 IRO-1 processes—originate from or connect to your strategy and business model, and how do they inform adaptations to it? Additionally, please describe the relationship between material risks and opportunities arising from impacts and dependencies on affected communities and your overall strategy and business model.
- Are all affected communities that are likely to be materially impacted by your organization—including through your operations, value chain, products/services, or business relationships—included in your disclosure under ESRS 2? If so, please provide: A brief description of the types of affected communities impacted by your operations or value chain, specifying whether they are: Communities near your operating sites, factories, or facilities, or more remote communities affected by these activities (e.g., downstream water pollution); Communities along your value chain (e.g., those affected by suppliers’ operations or logistics/distribution activities); Communities at one or both endpoints of the value chain (e.g., extraction sites, waste/recycling areas); Indigenous communities. For material negative impacts, indicate whether they are widespread/systemic (e.g., marginalized populations facing health/environmental risks) or related to individual incidents (e.g., toxic waste spills, community protests met with violence). Include any impacts linked to the transition to greener, climate-neutral operations (e.g., mine closures, increased mineral extraction, solar panel production). For material positive impacts, describe the activities driving these benefits (e.g., capacity-building for alternative livelihoods) and the communities affected, including any regional specifics if applicable. Any material risks and opportunities for your business arising from these impacts and dependencies on affected communities.
- How has your organization developed an understanding of how affected communities with specific characteristics, living in particular contexts, or engaged in certain activities may be at greater risk of harm, as identified in your ESRS 2 IRO-1 materiality assessment?
- Which of your material risks and opportunities, arising from impacts and dependencies on affected communities, apply specifically to particular groups rather than to all affected communities?
- How does your organization manage material impacts, risks, and opportunities related to affected communities? Please describe the policies you’ve adopted under ESRS 2 MDR-P and indicate whether these policies cover all affected communities or only specific groups.
- What specific policy provisions has your organization implemented to prevent and address impacts on indigenous peoples?
- How do your human rights policy commitments for affected communities—including specific provisions for indigenous peoples—ensure respect for their rights, facilitate engagement, and provide or enable remedies for human rights impacts? Please describe the processes and mechanisms you use to monitor compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises, and explain your overall approach in addressing these material issues.
- How do your policies regarding affected communities—and indigenous peoples in particular—align with internationally recognized standards, such as the UN Guiding Principles on Business and Human Rights? Additionally, to what extent have cases of non‑respect of these standards (including the ILO Declaration or OECD Guidelines) involving affected communities been reported in your operations or your upstream/downstream value chain, and what is the nature of these cases?
- How do the perspectives of affected communities inform your management of actual and potential impacts? Please describe whether engagement occurs directly with communities, their legitimate representatives, or credible proxies, including the stages, types, and frequency of this engagement; identify the function and most senior role responsible for ensuring effective engagement and integrating its outcomes; and explain how you assess the effectiveness of these engagement efforts, including any resulting agreements or outcomes.
- What steps does your organization take to gain insight into the perspectives of affected communities that are particularly vulnerable or marginalized, including specific groups such as women and girls?
- How does your organization ensure respect for the rights of indigenous peoples in its stakeholder engagement approach? Please explain how you address their right to free, prior and informed consent regarding: • Their cultural, intellectual, religious, and spiritual property; • Activities affecting their lands and territories; and • Legislative or administrative measures impacting them. Also, describe whether and how indigenous peoples have been consulted on the design, nature, and timing of the engagement process.
- Do you have a general process in place for engaging with affected communities? If not, please confirm its absence and provide a planned timeframe for establishing such a process.
- How does your organization address material negative impacts on affected communities? Please describe your overall approach and processes for providing or contributing to remedy—including how you assess the effectiveness of these remedies—the specific channels available for affected communities to raise concerns (whether established internally or through third-party mechanisms), the processes supporting the availability of these channels via your business relationships, and how you track, monitor, and ensure their effectiveness through stakeholder involvement.
- How does your organization assess whether affected communities are aware of and trust the channels available for raising their concerns and needs, and do you have policies in place to protect those who use these channels from retaliation? If you have already disclosed this information under ESRS G1-1, please refer to that disclosure.
- Do you have a dedicated channel for raising concerns for affected communities or ensuring such channels are available through your business relationships? If not, please confirm its absence and provide any planned timeframe for establishing such channels.
- What actions have you taken, planned, or are underway to prevent or mitigate material negative impacts on affected communities, and how have you provided or enabled remedy for actual material impacts? Additionally, please describe any initiatives aimed at delivering positive impacts and explain how you track and assess the effectiveness of these actions and initiatives.
- How does your organization determine and implement the necessary actions in response to actual or potential negative impacts on affected communities? Please explain your process for identifying appropriate actions, your approach to responding to material negative impacts—including those related to land acquisition, planning, construction, operations, or closures, as well as any wider collaborative efforts—and how you ensure that remedy processes are available and effective.
- How does your organization address material risks and opportunities related to affected communities? Please describe the actions planned or underway to mitigate risks—including how you track their effectiveness—and the actions planned or underway to pursue opportunities in this context.
- How does your organization ensure that its own practices avoid causing or contributing to material negative impacts on affected communities? In your answer, please describe your approach in areas such as planning, land acquisition and exploitation, finance, extraction or production of raw materials, natural resource use, and environmental impact management. Additionally, explain how you address tensions between mitigating negative impacts and other business pressures.
- Have any severe human rights issues or incidents connected to affected communities been reported? If so, please provide the relevant details.
- If you evaluate the effectiveness of your actions by setting targets, how do you track progress against these targets in accordance with ESRS 2 MDR-T? Please describe your target-setting process, tracking methods, and performance indicators used to assess the effectiveness of your policies and actions.
- What resources does your organization allocate to manage its material impacts, and how do these resources support effective impact management (e.g., financial, human, technological)?
- What are the summarised targets your organization has set to manage material impacts, risks, and opportunities related to affected communities, and how do these targets meet the information requirements specified in ESRS 2 MDR-T?
- How does your organization set targets to manage material impacts, risks, and opportunities related to affected communities? In your response, please explain: • How you engage directly with affected communities, their legitimate representatives, or credible proxies during target setting; • How you track performance against these targets; and • How you identify lessons learned or improvements based on your performance.
ESRS S4 Consumers and End-users
- How do actual and potential impacts on consumers and/or end‑users—as identified through your ESRS 2 IRO-1 processes—originate from or connect to your strategy and business model, and how do they contribute to its adaptation? Additionally, please explain the relationship between material risks and opportunities arising from impacts and dependencies on consumers and/or end‑users and your overall strategy and business model.
- Are all consumers and/or end-users who are likely to be materially impacted by your organization—including through your operations, value chain, products/services, or business relationships—included in your disclosure under ESRS 2? If so, please provide: A brief description of the types of consumers and/or end-users affected by your operations or value chain, specifying whether they are: Users of products that are inherently harmful or increase chronic disease risks; Users of services that might negatively affect their privacy, data protection, freedom of expression, or non-discrimination rights; Users who rely on accurate and accessible product/service information (e.g., manuals, labels) to avoid harm; Consumers who are particularly vulnerable to health, privacy, or marketing impacts (e.g., children, financially vulnerable individuals). For material negative impacts, indicate whether they are widespread/systemic (e.g., state surveillance affecting user privacy) or linked to individual incidents (e.g., a defective product) or specific business relationships (e.g., a partner using unethical marketing strategies targeting young consumers). For material positive impacts, describe the activities generating these benefits (e.g., product design improvements for accessibility) and the types of consumers/end-users affected, including any regional specifics if applicable. Any material risks and opportunities for your business arising from these impacts and dependencies on consumers and/or end-users.
- How has your organization, based on its ESRS 2 IRO-1 materiality assessment, developed an understanding of how consumers and/or end‑users with specific characteristics or those using particular products or services may be at greater risk of harm?
- Which material risks and opportunities arising from impacts and dependencies on consumers and/or end‑users apply specifically to certain groups (e.g., particular age groups) rather than to the entire consumer base?
- How does your organization manage material impacts, risks, and opportunities related to consumers and/or end‑users? Please describe the policies adopted under ESRS 2 MDR-P and indicate whether these policies apply to all consumers/end‑users or only to specific groups.
- How does your organization articulate its human rights policy commitments for consumers and/or end‑users, including the processes and mechanisms to monitor compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises? Please explain your general approach to: • Respecting the human rights of consumers/end‑users; • Engaging with them; and • Providing or enabling remedies for human rights impacts.
- How are your policies regarding consumers and/or end‑users aligned with internationally recognized standards, including the UN Guiding Principles on Business and Human Rights? Additionally, to what extent have violations of the UN Global Compact principles and the OECD Guidelines for Multinational Enterprises involving consumers/end‑users been reported in your downstream value chain, and what is the nature of these cases, if any?
- How do the perspectives of consumers and/or end‑users inform your decisions and activities for managing their actual and potential impacts? Please explain whether engagement occurs directly with consumers (or their legitimate representatives/credible proxies), the stages, types, and frequency of such engagement, the function and senior role responsible for ensuring this engagement and integrating its results, and how you assess its effectiveness—including any resulting agreements or outcomes.
- What steps does your organization take to gain insight into the perspectives of consumers and/or end‑users who may be particularly vulnerable or marginalized (e.g., people with disabilities, children)?
- Do you have a general process to engage with consumers and/or end‑users? If not, please confirm its absence and specify any planned timeframe for establishing such a process.
- How does your organization provide remedy when it has caused or contributed to a material negative impact on consumers and/or end‑users? Please describe your overall approach and processes for remedy—including how you assess their effectiveness—detail the channels available for consumers to raise concerns (whether established internally or via third‑party mechanisms), explain how you support or require these channels through your business relationships, and outline how you track and monitor raised issues, including stakeholder involvement in ensuring channel effectiveness.
- How does your organization assess whether consumers and/or end‑users are aware of and trust the available channels for raising concerns, and do you have policies in place to protect them from retaliation? If you have already disclosed this under ESRS G1-1, please refer to that information.
- Do you have a dedicated channel for raising concerns or ensuring such mechanisms are available through your business relationships? If not, please confirm its absence and, if applicable, provide a timeframe for when you plan to implement such a channel or process.
- Please provide a summarised description of your action plans and the resources allocated to manage material impacts, risks, and opportunities related to consumers and end‑users, in line with ESRS 2 MDR-A.
- What actions has your organization taken, planned, or are underway to prevent, mitigate, or remediate material negative impacts on consumers and end‑users, and how have you provided remedy for any actual impacts? Additionally, please describe any initiatives aimed at positively contributing to improved social outcomes for these stakeholders, and explain how you track and assess the effectiveness of these actions and initiatives.
- How does your organization identify and respond to actual or potential negative impacts on consumers and/or end‑users? Please describe the processes you use to determine the appropriate actions, your approach to addressing specific negative impacts—including any changes in product design, marketing, or sales practices and any collaborative industry actions—and how you ensure that remedy processes are available and effective.
- What actions are planned or underway to mitigate material risks arising from your impacts and dependencies on consumers and/or end‑users, and how do you track their effectiveness? Additionally, what actions are planned or underway to pursue material opportunities related to consumers and/or end‑users?
- How does your organization take action to avoid causing or contributing to material negative impacts on consumers and/or end‑users through its own practices, particularly in marketing, sales, and data use? Additionally, how do you manage tensions between preventing or mitigating these impacts and other business pressures?
- Have any severe human rights issues or incidents related to your consumers and/or end‑users been reported? If so, please disclose the details.
- If you set targets to evaluate the effectiveness of your remedy processes for material negative impacts on consumers and/or end‑users, how do you track progress against these targets in line with ESRS 2 MDR-T requirements?
- What resources does your organization allocate to manage its material impacts, and how do these resources support effective impact management?
- What are the summarised targets your organization has set to manage its material impacts, risks, and opportunities related to consumers and/or end‑users, ensuring that these targets meet the information requirements specified in ESRS 2 MDR-T?
- How does your organization set targets to manage material impacts, risks, and opportunities related to consumers and/or end‑users? Please describe your process—including how you engage directly with consumers, their legitimate representatives, or credible proxies during target setting, how you track performance against these targets, and how you identify any lessons or improvements from your performance.
ESRS G1 Business Conduct
- How does your organization establish, develop, promote, and evaluate its corporate culture?
- How does your organization ensure robust business conduct through its policies? Please describe how you: • Identify, report, and investigate concerns about unlawful behavior or breaches of your code of conduct—including whether internal and external stakeholders can report such concerns; • Address anti-corruption and anti-bribery measures in line with the United Nations Convention against Corruption (or, if not, whether you plan to implement such policies and the timeline for implementation); • Protect whistleblowers by establishing internal reporting channels (including staff training and designation) and implementing measures against retaliation in accordance with applicable law (e.g., Directive (EU) 2019/1937), or, if no such policies exist, your plans to implement them and the timetable; • Promptly, independently, and objectively investigate business conduct incidents (including corruption and bribery); • (If applicable) Address animal welfare through dedicated policies; • Provide training on business conduct, specifying the target audience, frequency, and depth of coverage; and • Identify the organizational functions most at risk of corruption and bribery.
- How does your organization prevent, detect, and address allegations or incidents of corruption and bribery? Please describe the procedures in place, indicate whether the investigators or investigating committee are independent from the management involved, and explain the process for reporting outcomes to your administrative, management, and supervisory bodies.
- If your organization does not have procedures in place to prevent, detect, and address allegations or incidents of corruption and bribery, please confirm this and provide details on any plans or timelines for adopting such procedures.
- How does your organization communicate its policies to relevant stakeholders to ensure they are accessible and well understood? Please describe the methods and channels used, as well as any training or awareness initiatives implemented.
- How does your organization approach anti-corruption and anti-bribery training? Please describe the nature, scope, and depth of your training programs, indicate the percentage of functions-at-risk covered, and explain the extent to which members of your administrative, management, and supervisory bodies participate in these programs.
- What is the total number of convictions your organization has received for anti-corruption and anti-bribery violations, and what is the total amount of fines incurred for these
- What actions have you taken to address breaches in your anti-corruption and anti-bribery procedures and standards?
- Have any incidents involving actors in your value chain been reported in which your organization or its employees were directly involved? If so, please provide details.
- Who in your administrative, management, or supervisory bodies is responsible for overseeing these activities?
- What is the total monetary value of both financial and in-kind political contributions made directly or indirectly by your organization—aggregated by country or geographical area and by recipient type—and how do you estimate the value of in-kind contributions (if applicable)?
- What are the main topics covered by your lobbying activities and what are your organization’s primary positions on these topics? Please explain how these topics relate to the material impacts, risks, and opportunities identified in your materiality assessment per [draft] ESRS 2.
- If your organization is registered in the EU Transparency Register or an equivalent register in a Member State, what is the name of the register and your identification number?
- Have any members of your administrative, management, or supervisory bodies held comparable positions in public administration (including regulators) in the two years preceding their appointment during the current reporting period? If so, please provide details.
- What is the average time (in days) your organization takes to pay an invoice from the date when the contractual or statutory payment term begins?
- What are your standard payment terms (in days) for each main category of suppliers, and what percentage of payments are made in accordance with these terms?
- How many legal proceedings for late payments are currently outstanding during the reporting period?
- Please provide any complementary information necessary to contextualize these payment practices.