Questions & Answers
Separating HR policies (ESRS S1-1), action plans (ESRS S1-4), targets (ESRS S1-5) and metrics (ESRS S1-9 to S1-17) is not efficient for the understanding of users. Can we put into one chapter, for each material issue (e.g., health and safety), the policy with the targets, the action plan, and the metrics?
- Structure of the sustainability statement
Background
ESRS 1 chapter 8 provides the basis for the presentation of information about sustainability matters prepared in compliance with Articles 19a and 29a of Directive 2013/34/EU (i.e., the sustainability statement) within the undertaking’s management report.
ESRS 2 paragraph 49 states: ‘The undertaking may disclose the descriptive information required in paragraph 46 – ESRS 2 SBM-3 – alongside the disclosures provided under the corresponding topical ESRS, in which case it shall still present a statement of its material impacts, risks and opportunities alongside its disclosures prepared under this chapter of ESRS 2.’
ESRS S1 paragraph 11 specifies that the ESRS 2 General disclosures in topical standards shall be presented alongside the disclosures required by ESRS 2 except for ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model, for which the undertaking has an option to present the disclosures alongside the topical disclosures.
Answer
In relation to the presentation of information required by a topical standard, flexibility is provided to the undertaking as there are no specific requirements defining how an undertaking shall present the reported information related to a specific topic required by a given topical standard.
Therefore, for a given material matter (for example, health and safety) the undertaking may present the applicable disclosures on policies, actions, targets and metrics all together and does not have to follow the structure of the disclosure requirements within the topical standard, such as ESRS S1 Own workforce.
Regarding the overall sustainability reporting, ESRS 1 paragraph 115 clarifies that the sustainability statement must be structured in four parts: ‘general information, environmental information, social information and governance information’. A particular treatment is anticipated for ESRS 2 SBM-3 related disclosures[1] required by topical standards, which can be either presented alongside the other ESRS 2 General disclosures or alongside the respective topical disclosures (environmental, social and governance). In case the ESRS 2 General disclosures required by topical standards are presented alongside other topical disclosures, the undertaking still has to present a statement of its material impacts, risks and opportunities alongside its disclosures prepared under ESRS 2 SBM-3. Appendix F of ESRS 1 provides a non-binding structure for a sustainability statement.
Relations
Paragraph | Content |
|---|---|
Appendix F - Example of structure of ESRS sustainability statement | |
8. Structure of the sustainability statement | |
Appendix F - Example of structure of ESRS sustainability statement | |
8. Structure of the sustainability statement | |
Appendix F - Example of structure of ESRS sustainability statement | |
8. Structure of the sustainability statement | |
The requirements of this section should be read in conjunction with the disclosures required by ESRS 2 on Strategy (SBM). The resulting disclosures shall be presented alongside the disclosures required by ESRS 2, except for ESRS 2 SBM-3, for which the undertaking has an option to present the disclosures alongside the topical disclosure. | |
The requirements of this section should be read in conjunction with the disclosures required by ESRS 2 on Strategy (SBM). The resulting disclosures shall be presented alongside the disclosures required by ESRS 2, except for ESRS 2 SBM-3, for which the undertaking has an option to present the disclosures alongside the topical disclosure. | |
The requirements of this section should be read in conjunction with the disclosures required by ESRS 2 on Strategy (SBM). The resulting disclosures shall be presented alongside the disclosures required by ESRS 2, except for ESRS 2 SBM-3, for which the undertaking has an option to present the disclosures alongside the topical disclosure. |