Questions & Answers

Question-ID: 800

Release Date: Oct 31, 2024


Questions & Answers

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?

Key Terms
  • Corruption
  • bribery

Background

ESRS G1 paragraph 24 states: ‘The undertaking shall disclose:

(a) the number of convictions and the amount of fines for violation of anti-corruption and anti-bribery laws; and

(b) any actions taken to address breaches in procedures and standards of anti-corruption and anti-bribery.’

ESRS G1 paragraph 25 states: ‘The undertaking may disclose:

(a) the total number and nature of confirmed incidents of corruption or bribery …’

Answer

There is no requirement to distinguish between convictions or fines for corruption and those for bribery in paragraph 24 of ESRS G1. Additional information about the nature of the conviction or fine is voluntary.

‘Confirmed incidents of corruption/bribery’ is the subject of voluntary disclosures per paragraph 25 of ESRS G1, which requires disclosure of the nature. There is no concept of ‘incidents of corruption or bribery’ in ESRS.


Relations

Paragraph
Content
2023 ESRSESRS G1 - BUSINESS CONDUCT...Metrics and targets25.

The undertaking may disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirements24.

The undertaking shall disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirement G1-4 – Incidents of corruption or bribery25.

The undertaking may disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Metrics and targets24.

The undertaking shall disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Metrics and targets25.

The undertaking may disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCTDisclosure Requirements24.

The undertaking shall disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCTDisclosure Requirement G1-4 – Incidents of corruption or bribery25.

The undertaking may disclose:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Metrics and targets24.

The undertaking shall disclose: