Questions & Answers

Question-ID: 293

Release Date: Apr 30, 2024


Questions & Answers

What is developed first: the strategy or the policy related to sustainability matters?

Key Terms
  • Strategy
  • policy

Background

ESRS 2 paragraph 38 states: ‘The undertaking shall disclose the elements of its strategy that relate to or impact sustainability matters, its business model and its value chain.’

ESRS 2 paragraph 63 states: ‘The undertaking shall apply the minimum disclosure requirements defined in this provision when it discloses the policies it has in place with regard to each sustainability matter identified as material.’

A policy according to the Annex II Acronyms and Glossary of Terms is ‘A set or framework of general objectives and management principles that the undertaking uses for decision-making. A policy implements the undertaking’s strategy or management decisions related to a material sustainability matter.’

Answer

While ESRS set disclosure requirements, they do not prescribe behavioural obligations in respect to strategy and policies.

The development of a strategy or policy related to sustainability matters is determined by the undertaking’s governance bodies.


Relations

Paragraph
Content
2023 ESRSESRS 2 - GENERAL DISCLOSURES3. StrategyDisclosure Requirement SBM-1 – Strategy, business model and value chain

Disclosure Requirement SBM-1 – Strategy, business model and value chain

2023 ESRSESRS 2 - GENERAL DISCLOSURES3. StrategyDisclosure Requirement SBM-1 – Strategy, business model and value chain

Disclosure Requirement SBM-1 – Strategy, business model and value chain

2023 ESRSESRS 2 - GENERAL DISCLOSURES3. StrategyDisclosure Requirement SBM-1 – Strategy, business model and value chain

Disclosure Requirement SBM-1 – Strategy, business model and value chain

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