Questions & Answers

ESRS E4-5 paragraph 37 mentions that ‘For datapoints specified in paragraphs 38 to 41, the undertaking shall consider its own operations’. Does that mean that ESRS E4 paragraph 33 where it says ‘The undertaking shall report metrics related to its material impacts on biodiversity and ecosystems’ also refers to the undertaking’s own operations only?

Is the ESRS 1 Disclosure Requirement SBM-3 metric to be reported for ESRS E4 if biodiversity was assessed as not material for the company’s own operations but material only for the upstream value chain? The SBM-3 metric specifically refers to the company’s own sites, i.e. own operations. Additionally, no sites were found located in or near biodiversity-sensitive areas that have negative impacts on these areas.

ID 1033: In the context of ESRS E1 paragraph 34 (a) and in a situation where a credit institution has set GHG emissions intensity targets, are credit institutions expected to provide associated absolute values in relation to their emissions intensity targets even if such metric is not used to steer the portfolio and due to the fact that it can be neither predictive or of confirmatory value due to the business model of the credit institutions?

ID 1076: Would it be possible for a financial institution to disclose GHG emissions targets set on Scope 3 category 15 (i.e. ‘financed emissions’) without reporting the corresponding targets in absolute emissions?’

ID 1122: Regarding absolute values for financial institutions – why not show exposure and exposure percentages instead of GHG emissions?’

If the company has an intensity-emission-reduction target already set with a different base year than the ESRS recommend (e.g. 2021) but no absolute target yet, is it okay to use the same base year as for the intensity target although it does not follow the ESRS recommendation?

What is the definition of ‘projects’ in ESRS E1 paragraph 56 (a)? Is this related to investments / asset-driven initiatives which establish a new facility, process, technology and the like?

Should the percentage of contractual instruments be calculated in terms of electricity consumption, not in terms of Scope 2 GHG emissions?

The guideline stipulates that deviations of more than 5% per employee category must be justified. How are these categories defined? If the reporting pay demonstrates a difference in the average pay level of at least 5 % in any category of workers, the employer needs to justify such a difference on the basis of objective, gender-neutral criteria – otherwise, joint pay assessment is necessary.

Could you please specify the short-term time horizon?

For a material matter, if the undertaking assesses that a Disclosure Requirement is not material, is it possible to conclude that a datapoint of such Disclosure Requirement is material and therefore included?

There is a reference to Division 20.2 of Annex I to Regulation (EC) No 1893/2006 and I wonder whether you mean Division 20 Group 20.2, which is ‘Manufacture of pesticides and other agrochemical products’.

May non-exempt employees of an employer who are bound by a collective wage agreement be omitted when calculating the gender pay gap (at least when broken down by employee category)?

Does gender pay gap only have to be calculated for ‘female’ and ‘male’ genders? If so, where should employees who have specified a different gender be categorised? Or is the calculation based on the gender categories ‘female’, ‘male’, ‘diverse’/’other’?

Many datapoints in the S1 have to be broken down by gender. Which definition of ‘gender’ is used in the ESRS? Is it only the female-male categories or should answers contain a third, ‘diverse’ category or more categories when breaking down information by gender?

How can one document ESG knowledge and the competences of the management board and supervisory board? Should it be one person from the Management Board or the Supervisory Board who has these features or else the entire Management Board and the entire Supervisory Board? Can it be an attorney? Should it be a course, training or, for example, studies?

ID 271: What is the difference between work-related accident and work-related injury?

ID 287: What is the difference between an ‘accident’ and an ‘injury’, and how should I count a ‘case’?

Is the understanding correct that undertakings can add the amount of emissions reduced before their new base year to the actual emissions of the new base year and therefore suggest that the past emissions have not been realised?

What does ‘type of employee’ mean for the purposes of Disclosure Requirement ESRS S1-11 Social Protection?

Is incineration with energy recovery considered waste diverted or waste disposed?

If the matter of GHG emissions is material, should the undertaking also report under the ESRS E2 in addition to ESRS E1?

Does an undertaking need to disclose the total number of incidents of corruption and the total number of incidents of bribery, or is there some additional data needed about the ‘nature’ of each type of incident?