APPENDIX
Table of content
| Datapoints derived from other EU legislation | ||||||
| Disclosure Requirements | Scope | Page | SFDR | Pillar 3 | Benchmark-Regulation | EU Climate Law |
| ESRS 2 General Disclosures | ||||||
| BP-1 – General basis for preparation of sustainability statements | Covered | 44 | ||||
| BP-2 – Disclosures in relation to specific circumstances | Covered | 44-45 | ||||
| GOV-1 – The role of the administrative, management and supervisory bodies | Covered | 46 | §21 (d) | §21 (d), (e) | ||
| GOV-2 – Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies | Covered | 47 | ||||
| GOV-3 – Integration of sustainability-related performance in incentive schemes | Covered | 47 | ||||
| GOV-4 – Statement on due diligence | Covered | 47 | §30 | |||
| GOV-5 – Risk management and internal controls over sustainability reporting | Covered | 48 | ||||
| SBM-1 – Strategy, business model and value chain | Covered | 48-51 | §40 (d) i, ii, iii | §40 (d) i | §40 (d) i, ii, iii, iv | |
| SBM-2 – Interests and views of stakeholders | Covered | 51 | ||||
| SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model | Covered | 51-55 | ||||
| IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities | Covered | 56 | ||||
| IRO-2 – Disclosure Requirements in ESRS Covered by the Undertaking’s Sustainability Statement | Covered | 86-88 | ||||
| E1 Climate change | ||||||
| ESRS 2 GOV-3 – Integration of sustainability-related performance in incentive schemes | Covered | 47 | ||||
| E1-1 – Transition plan for climate change mitigation | Covered | 58 | §16 (g) | §16 (g) | §14 | |
| ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model | Covered | 58 | ||||
| ESRS 2 IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities | Covered | 57, 61 | ||||
| E1-2 – Policies related to climate change mitigation and adaptation | Covered | 58 | ||||
| E1-3 – Actions and resources in relation to climate change policies | Covered | 58-59 | ||||
| E1-4 – Targets related to climate change mitigation and adaptation | Covered | 59 | §34 | §34 | §34 | |
| E1-5 – Energy consumption and mix | Covered | 59 | §38, §37, §40-43 | |||
| E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions | Covered | 60-62 | §44, §53-55 | §44, §53-55 | §44, §53-55 | |
| E1-7 – GHG removals and GHG mitigation projects financed through carbon credits | Not material | – | §56 | |||
| E1-8 – Internal carbon pricing | Not material | – | ||||
| E1-9 – Anticipated financial effects from material physical and transition risks and potential climate-related opportunities | Phase in | – | §66 (a), (c), §67 (c) | §66, §69 | ||
| E2 Pollution | ||||||
| ESRS 2 IRO-1 - Description of the processes to identify and assess material pollution-related impacts, risks and opportunities | Covered | 63 | ||||
| E2-1 – Policies related to pollution | Covered | 63, 81-82 | ||||
| E2-2 – Actions and resources related to pollution | Covered | 60, 83 | ||||
| E2-3 – Targets related to pollution | Covered | 63, 84 | ||||
| E2-4 – Pollution of air, water, and soil | Not material | – | §28 | |||
| E2-5 – Substances of concern and substances of very high concern | Not material | - | ||||
| E2-6 – Anticipated financial effects from pollution-related impacts, risks, and opportunities | Not material | - | ||||
| E3 Water and marine resources | ||||||
| ESRS 2 IRO-1 – Description of the processes to identify and assess material water and marine resources-related impacts, risks and opportunities | Not material | – | ||||
| E3-1 – Policies related to water and marine resources | Not material | – | §9, §13, §14 | |||
| E3-2 – Actions and resources related to water and marine resources | Not material | – | ||||
| E3-3 – Targets related to water and marine resources | Not material | – | ||||
| E3-4 – Water consumption | Not material | – | §28 (c), §29 | |||
| E3-5 – Anticipated financial effects from water and marine resources-related impacts, risks and opportunities | Not material | – | ||||
| E4 Biodiveristy and ecosystems | ||||||
| E4-1 – Transition plan and consideration of biodiversity and ecosystems in strategy and business model | Covered | 64 | ||||
| ESRS 2 SBM-3 – Material impacts, risks, and opportunities and their interaction with strategy and business model | Not material | - | §16 (a), (b), (c) | |||
| ESRS 2 IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities | Covered | 64 | ||||
| E4-2 – Policies related to biodiversity and ecosystems | Covered | 64, 81-82 | §24 (b), (c), (d) | |||
| E4-3 – Actions and resources in relation to climate change policies | Covered | 64, 83 | ||||
| E4-4 – Targets related to biodiversity and ecosystems | Covered | 65, 84 | ||||
| E4-5 – Impact metrics related to biodiversity and ecosystem change | Not material | – | ||||
| E4-6 – Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities | Not material | – | ||||
| E5 Resource use and circular economy | ||||||
| ESRS 2 IRO-1 – Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities | Covered | 65 | ||||
| E5-1 – Policies related to resource use and circular economy | Covered | 65, 81-82 | ||||
| E5-2 – Actions and resources related to resource use and circular economy | Covered | 65-66, 83 | ||||
| E5-3 – Targets related to resource use and circular economy | Covered | 66, 84 | ||||
| E5-4 – Resource inflows | Covered | 66 | ||||
| E5-5 – Resource outflows | Phase in | – | §37 (d), §39 | |||
| E5-6 – Anticipated financial effects from resource use and circular economy-related impacts, risks, and opportunities | Phase in | – | ||||
| S1 Own workforce | ||||||
| ESRS 2 SBM-2 – Interests and views of stakeholders | Covered | 51 | ||||
| ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model | Covered | 69 | §14 (f), (g) | |||
| S1-1 – Policies related to own workforce | Covered | 69, 81-82 | §20, §22, §23 | §21 | ||
| S1-2 – Processes for engaging with own workers and workers’ representatives about impacts | Covered | 70 | ||||
| S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns | Covered | 70, 82 | §32 (c) | |||
| S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions | Covered | 70-71 | ||||
| S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Covered | 72 | ||||
| S1-6 – Characteristics of the undertaking’s employees | Covered | 73, 76 | ||||
| S1-7 – Characteristics of non-employee workers in the undertaking’s own workforce | Not material | – | ||||
| S1-8 – Collective bargaining coverage and social dialogue | Covered | 73 | ||||
| S1-9 – Diversity metrics | Covered | 74 | ||||
| S1-10 – Adequate wages | Not material | – | ||||
| S1-11 – Social protection | Not material | – | ||||
| S1-12 – Persons with disabilities | Not material | – | ||||
| S1-13 – Training and skills development metrics | Covered | 75, 76 | ||||
| S1-14 – Health and safety metrics | Covered | 75-76 | §88 (b), (c), (e) | §88 (b), (c) | ||
| S1-15 – Work-life balance metrics | Not material | - | ||||
| S1-16 – Remuneration metrics, pay gap and total remuneration | Covered | 75-76 | §97 (a), (b) | §97 (a) | ||
| S1-17 – Incidents, complaints and severe human rights impacts | Covered | 76 | §103 (a), §104 (a) | §104 (a) | ||
| S2 Workers in the value chain | ||||||
| ESRS 2 SBM-2 Interests and views of stakeholders | Covered | 51 | §11 (b) | |||
| ESRS 2 SBM-3 – Material impacts, risks, and opportunities and their interaction with strategy and business model | Covered | 77, 83 | ||||
| S2-1 – Policies related to value chain workers | Covered | 77, 81-82 | §17, §18, §19 | §19 | ||
| S2-2 – Processes for engaging with value chain workers about impacts | Covered | 77, 83 | ||||
| S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns | Covered | 78, 82 | ||||
| S2-4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those action | Covered | 78, 83 | §36 | |||
| S2-5: Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Covered | 78, 84 | ||||
| S3 Affected communities | ||||||
| ESRS 2 SBM-2 – Interests and views of stakeholders | Not material | - | ||||
| ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model | Not material | - | ||||
| S3-1 – Policies related to affected communities | Not material | - | §16, §17 | §17 | ||
| S3-2 – Processes for engaging with affected communities about impacts | Not material | - | ||||
| S3-3 – Processes to remediate negative impacts and channels for affected communities to raise concerns | Not material | - | ||||
| S3-4 – Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions | Not material | - | §36 | |||
| S3-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Not material | - | ||||
| S4 Consumers and end-users | ||||||
| ESRS 2 SBM-2 – Interests and views of stakeholders | Covered | 51 | ||||
| ESRS 2 SBM-3 – Material impacts, risks, and opportunities and their interaction with strategy and business model | Covered | 79 | ||||
| S4-1 – Policies related to consumers and end-users | Covered | 79, 81-82 | §16, §17 | §17 | ||
| S4-2 – Processes for engaging with consumers and end-users about impacts | Covered | 76 | ||||
| S4-3 – Processes to remediate negative impacts and channels for consumers and end-users to raise concerns | Covered | 80, 82 | ||||
| S4-4 – Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions | Covered | 80 | §35 | |||
| S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Covered | 80 | ||||
| G1 Business conduct | ||||||
| ESRS 2 GOV-1 – The role of the administrative, supervisory, and management bodies | Covered | 46 | ||||
| ESRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities | Covered | 81 | ||||
| G1-1 – Business conduct policies and corporate culture | Covered | 81-82 | §10 (b), (d) | |||
| G1-2 – Management of relationships with suppliers | Covered | 83 | ||||
| G1-3 – Prevention and detection of corruption and bribery | Covered | 84 | ||||
| G1-4 – Incidents of corruption or bribery | Covered | 85 | §24 (a), (b) | §24 (a) | ||
| G1-5 – Political influence and lobbying activities | Not material | – | ||||
| G1-6 – Payment practices | Not material | – | ||||