ESRS Index

The contents of this sustainability report were identified on the basis of the double materiality analysis. The exact procedure for the dual materiality analysis can be found in the section IRO-1 Description of the process to identify and assess material impacts, risks and opportunities. The selection of datapoints was based on the results of the materiality analysis. Based on this, the materiality and applicability of individual datapoints were also evaluated on a case-by-case basis. In addition, the material company-specific topics are disclosed through concepts, measures, and goals in accordance with the structure of the ESRS.

The following is a summary of all datapoints resulting from other EU legislation listed in ESRS 2 Annex B, including references to the relevant page number or information that the datapoint was not considered material.

List of datapoints in cross-cutting and topical standards that derive from other EU legislation (ESRS 2 Annex B)

Disclosure Requirement	Description	SFDR reference¹	Pillar 3 reference²	Benchmark Regulation reference³	EU Climate Law reference⁴	Materiality	Name with reference
ESRS 2 GOV-1	Board’s gender diversity paragraph 21 (d)	Indicator number 13 Table #1 of Annex 1		Commission Delegated Regulation (EU) 2020/1816 ⁵, Annex II		Material	The role of the administrative, management, and supervisory bodies
ESRS 2 GOV-1	Percentage of board members who are independent paragraph 21 (e)			Commission Delegated Regulation (EU) 2020/1816, Annex II		Material	The role of the administrative, management, and supervisory bodies
ESRS 2 GOV-4	Statement on due diligence paragraph 30	Indicator number 10 Table #3 of Annex 1				Material	Statement on due diligence
ESRS 2 SBM-1	Involvement in activities related to fossil fuel activities paragraph 40 (d) i	Indicators number 4 Table #1 of Annex 1	Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453⁶ Table 1: Qualitative information on Environmental risk and Table 2: Qualitative information on Social risk	Commission Delegated Regulation (EU) 2020/1816, Annex II		Immaterial	n.a.
ESRS 2 SBM-1	Involvement in activities related to chemical production paragraph 40 (d) ii	Indicator number 9 Table #2 of Annex 1		Commission Delegated Regulation (EU) 2020/1816, Annex II		Immaterial	n.a.
ESRS 2 SBM-1	Involvement in activities related to controversial weapons paragraph 40 (d) iii	Indicator number 14 Table #1 of Annex 1		Delegated Regulation (EU) 2020/1818⁷, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II		Immaterial	n.a.
ESRS 2 SBM-1	Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv			Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II		Immaterial	n.a.
ESRS E1-1	Transition plan to reach climate neutrality by 2050 paragraph 14				Regulation (EU) 2021/1119 Article 2(1)	Material	Transition plan for climate change mitigation
ESRS E1-1	Undertaktings excluded from Paris-aligned Benchmarks paragraph 16 (g)		Article 449a Regulation (EU) No 575/2013 Template 1: Banking book-Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity	Delegated Regulation (EU) 2020/1818, Article 12.1 (d) to (g), and Article 12.2		Material	Transition plan for climate change mitigation
ESRS E1-4	GHG emission reduction targets paragraph 34	Indicator number 4 Table #2 of Annex 1	Article 449a Regulating (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics	Delegated Regulation (EU) 2020/1818, Article 6		Material	Targets related to climate change mitigation and adaption
ESRS E1-5	Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38	Indicator number 5 Table #1 and Indicator number 5 Table #2 of Annex 1				Material	Energy consumption and mix
ESRS E1-5	Energy consumption and mix paragraphes 37	Indicator number 5 Table #1 of Annex 1				Material	Energy consumption and mix
ESRS E1-5	Energy intensity associated with activities in high climate impact sectors paragraphes 40 to 43	Indicator number 6 Table #1 of Annex 1				Material	Energy consumption and mix
ESRS E1-6	Gross Scope 1, 2, 3 and Total GHG emmission paragraph 44	Indicator number 1 and 2 Table #1 of Annex 1	Article 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate change transition risk: Credit quality of exposures by sector, emission and residual maturity	Delegation Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1)		Material	Gross Scopes 1,2,3 and total GHG emissions
ESRS E1-6	Gross GHG emission intensity paragraphs 53 to 55	Indicators number 3 Table #1 Annex 1	Article 449a Regulation (EU) No 575/2013 ; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics	Delegated Regulation (EU) 2020/1818, Article 8(1)		Material	Gross Scopes 1,2,3 and total GHG emissions
ESRS E1-7	GHG removals and carbon credits paragraph 56				Regulation (EU) 2021/1119 Article 2(1)	Immaterial	n.a.
ESRS E1-9	Exposure of the benchmark portfolio to climate-related physical risks paragraph 66			Delegated Regulation (EU) 2020/1818, Annex II Delegated Regulation (EU) 2020/1816, Annex II		Transitional provision	n.a.
ESRS E1-9	Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a) Location of significant assets at material physical risk paragraph 66 (c)		Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraphs 46 and 47; Template 5: Banking book – Climate change physical risk: Exposures subject to physical risk			Transitional provision	n.a.
ESRS E1-9	Breakdown of the carrying value of ist real estate assets by energy-efficiency classes paragraph 67 (c)		Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 20022/2453 paragraph 34; Template 2: Banking book –Climate change transition risk: Loans collateralized by immovable property – Energy efficiency of the collateral			Transitional provision	n.a.
ESRS E1-9	Degree of exposure of the portfolio to climate-related opportunities paragraph 69			Commission Delegated Regulation (EU) 2020/1818, Annex II		Transitional provision	n.a.
ESRS E2-4	Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil paragraph 28	Indicator number 8 Table #1 of Annex 1 Indicator number 2 Table #2 of Annex 1 Indicator number 1 Table #2 of Annex 1 Indicator number 3 Table #2 of Annex 1				Material	Pollution of air, water, and soil
ESRS E3-1	Water and marine resources paragraph 9	Indicator number 7 Table #2 of Annex 1				Material	Policies related to water and marine resources
ESRS E3-1	Dedicated policy paragraph 13	Indicator number 8 Table #2 of Annex 1				Material	Policies related to water and marine resources
ESRS E3-1	Sustainable oceans and seas paragraphe 14	Indicator number 12 Table #2 of Annex 1				Immaterial	n.a.
ESRS E3-4	Total water recycled and reused paragraph 28 (c)	Indicator number 6.2 Table #2 of Annex 1				Material	Water consumption
ESRS E3-4	Total water consumption in m³ per net revenue on own operations paragraph 29	Indicator number 6.1 Table #2 of Annex 1				Material	Water consumption
ESRS 2 – IRO-1 – E4	paragraph 16(a) i	Indicator number 7 Table #1 of Annex 1				Material	Biodiversity and ecosystems
ESRS 2 – IRO-1 – E4	paragraph 16 (b)	Indicator number 10 Table #2 of Annex 1				Material	Biodiversity and ecosystems
ESRS 2 – IRO-1 – E4	paragraph 16 (c)	Indicator number 14 Table #2 of Annex 1				Material	Biodiversity and ecosystems
ESRS E4-2	Sustainable land/agriculture practices or policies paragraph 24(b)	Indicator number 11 Table #2 of Annex 1				Immaterial	n.a.
ESRS E4-2	Sustainable oceans / seas practices or policies paragraph 24 (c)	Indicator number 12 Table #2 of Annex 1				Immaterial	n.a.
ESRS E4-2	Policies to address deforestation paragraph 24 (d)	Indicator number 15 Table #2 of Annex 1				Immaterial	n.a.
ESRS E5-5	Non-recycled waste paragraph 37 (d)	Indicator number 13 Table #2 of Annex 1				Material	ESRS E5 Resource use and circular economy
ESRS E5-5	Hazardous waste and radioactive waste paragraph 39	Indicator number 9 Table #1 of Annex 1				Material	ESRS E5 Resource use and circular economy
ESRS 2 SBM-3 – S1	Risk of incidents of forced labour pararaph 14 (f)	Indicator number 13 Table #3 of Annex 1				Material	Own workforce
ESRS 2 SBM-3 – S1	Risk of incidents of child labour paragraph 14 (g)	Indicator number 12 Table #3 of Annex 1				Material	Own workforce
ESRS S1-1	Human rights policy commitments paragraph 20	Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1				Material	Policies related to own workforce
ESRS S1-1	Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 21			Commission Delegated Regulation (EU) 2020/1816 Annex II		Material	Policies related to own workforce
ESRS S1-1	processes and measures for preventing trafficking in human beings paragraph 22	Indicator number 11 Table #3 of Annex 1				Material	Policies related to own workforce
ESRS S1-1	workplace accident prevention policy or management system paragraph 23	Indicator number 1 Table #3 of Annex 1				Material	Policies related to own workforce
ESRS S1-3	grievance/complaints handling mechanisms paragraph 32 (c)	Indicator number 5 Table #3 of Annex 1				Material	Processes to remediate negative impacts and channels for own workers to raise concerns
ESRS S1-14	Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c)	Indicator number 2 Table #3 of Annex 1		Commission Delegated Regulation (EU) 2020/1816, Annex II		Material	health & safety metrics
ESRS S1-14	Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e)	Indicator number 3 Table #3 of Annex 1				Transitional provision	n.a.
ESRS S1-16	Unadjusted gender pay gap paragraph 97 (a)	Indicator number 12 Table #1 of Annex 1		Commission Delegated Regulation (EU) 2020/1816, Annex II		Material	Compensation metrics (pay gap and total compensation)
ESRS S1-16	Excessive CEO pay ratio paragraph 97 (b)	Indicator number 8 Table #3 of Annex 1				Material	Compensation metrics (pay gap and total compensation)
ESRS S1-17	Incidents od discrimination paragraph 103 (a)	Indicator number 7 Table #3 of Annex 1				Material	Incidents, complaints, and severe human rights impacts
ESRS S1-17	Non-respect of UNGPs on Business and Human Rights and OECD paragraph 104 (a)	Indicator number 10 Table #1 of Annex 1 and Indicator number 14 Table #3 of Annex 1		Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818 Art 12 (1)		Material	Incidents, complaints, and severe human rights impacts
ESRS 2 SBM-3 – S2	Significant risk of child labour or forced labour in the value chain paragraph 11 (b)	Indicators number 12 and number 13 Table #3 of Annex 1				Material	Workers in the value chain
ESRS S2-1	Human rights policy commitments paragraph 17	Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1				Material	Policies related to value chain workers
ESRS S2-1	Policies related to value chain workers paragraph 18	Indicators number 11 and 4 Table #3 of Annex 1				Material	Policies related to value chain workers
ESRS S2-1	Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines paragraph 19	Indicator number 10 Table #1 of Annex 1		Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1)		Material	Policies related to value chain workers
ESRS S2-1	Due diligence policies on issues adressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19			Commission Delegated Regulation (EU) 2020/1816, Annex II		Material	Policies related to value chain workers
ESRS S2-4	Human rights issues and incidents connected to its upstream and downstream value chain prargraph 36	Indicator number 14 Table #3 of Annex 1				Material	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 actions
ESRS S3-1	Human rights policy commitments paragraph 16	Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1				Material	Policies related to affected communities
ESRS S3-1	Non- respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17	Indicator number 10 Table #1 Annex 1		Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1)		Material	Policies related to affected communities
ESRS S3-4	Human rights issues and incidents paragraph 36	Indicator number 14 Table #3 of Annex 1				Material	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
ESRS S4-1	Policies related to consumers and end-users paragraph 16	Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex 1				Immaterial	n.a.
ESRS S4-1	Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17	Indicator number 10 Table #1 of Annex 1		Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1)		Immaterial	n.a.
ESRS S4-4	Human rights issues and incidents paragraph 35	Indicator number 14 Table #3 of Annex 1				Immaterial	n.a.
ESRS G1-1	United Nations Convention against Corruption paragraph 10 (b)	Indicator number 15 Table #3 of Annex 1				Immaterial	n.a.
ESRS G1-1	Protection of whistleblowers paragraph 10 (b)	Indicator number 6 Table #3 of Annex 1				Immaterial	n.a.
ESRS G1-4	Fines for violation of anti- corruption and anti-bribery laws paragraph 24 (a)	Indicator number 17 Table #3 of Annex 1		Commission Delegated Regulation (EU) 2020/1816, Annex II		Material	Confirmed incidents of corruption or bribery
ESRS G1-4	Standards of anti- corruption and anti- bribery paragraph 24 (b)	Indicator number 16 Table #3 of Annex 1				Material	Confirmed incidents of corruption or bribery
1 Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (Sustainable finance Disclosures Regulation) (OJ L 317, 9.12.2019, p. 1). 2 Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (Capital Requirements Regulation “CRR”) (OJ L 176, 27.6.2013, p. 1). 3 Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1). 4 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (“European Climate Law”) (OJ L 243, 9.7.2021, p. 1). 5 Commission Delegated Regulation (EU) 2020/1816 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards the explanation in the benchmark statement of how environmental, social and governance factors are reflected in each benchmark provided and published (OJ L 406, 3.12.2020, p. 1). 6 Commission Implementing Regulation (EU) 2022/2453 of 30 November 2022 amending the implementing technical standards laid down in Implementing Regulation (EU) 2021/637 as regards the disclosure of environmental, social and governance risks (OJ L 324,19.12.2022, p.1.). 7 Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks (OJ L 406, 3.12.2020, p. 17).
Below is a list of disclosure requirements (including references to the relevant ESRS disclosure) that were made when preparing this sustainability report based on the findings from the materiality assessment:

Disclosure and application requirements in topical ESRS that are applicable in conjunction with ESRS 2 General Disclosures

ESRS 2 – General Disclosures

Disclosure requirement		Name with reference
BP-1		General basis for preparation of sustainability reports
BP-2		Disclosures in relation to specific circumstances
GOV-1		The role of the administrative, management, and supervisory bodies
GOV-1 – G1		Business conduct
GOV-2		Information provided to and sustainability matters addressed by the undertaking’s administrative, management, and supervisory bodies
GOV-3		Integration of sustainability-related performance in incentive schemes
GOV-3 – E1		Climate change
GOV-4		Statement on due diligence
GOV-5		Risk management and internal controls over sustainability reporting
SBM-1		Strategy, business model, and value chain
SBM-2		Interests and views of stakeholders
SBM-2 – S1		Own workforce
SBM-2 – S2		Workers in the value chain
SBM-2 – S3		Affected communities
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
SBM-3 – E1		Climate change
SBM-3 – E4		Biodiversity and ecosystems
SBM-3 – S1		Own workforce
SBM-3 – S2		Workers in the value chain
SBM-3 – S3		Affected communities
IRO-1		Description of the process to identify and assess material impacts, risks, and opportunities
IRO-1 – E1		Climate change
IRO-1 – E2		Pollution
IRO-1 – E3		Water and marine resources
IRO-1 – E4		Biodiversity and ecosystems
IRO-1 – E5		Resource use and circular economy
IRO-1 – G1		Business conduct
IRO-2		Disclosure requirements in ESRS covered by the undertaking’s sustainability report

Environmental Information

Disclosure requirement		Name with reference
Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 /Taxonomy Regulation)

ESRS E1 – Climate change

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
E1-1		Transition plan for climate change mitigation
E1-2		Policies related to climate change mitigation and adaption
E1-3		Actions and resources in relation to climate change policies
E1-4		Targets related to climate change mitigation and adaption
E1-5		Energy consumption and mix
E1-6		Gross Scopes 1, 2, 3 and total GHG emissions

ESRS E2 – Pollution

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
E2-1		Policies related to pollution
E2-2		Actions and resources related to pollution
E2-3		Targets related to pollution
E2-4		Pollution of air, water, and soil

ESRS E3 – Water and marine resources

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
E3-1		Policies related to water and marine resources
E3-2		Actions and resources related to water and marine resources
E3-3		Targets related to water and marine resources
E3-4		Water consumption

ESRS E4 – Biodiversity and ecosystems

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
E4-1		Transition plan and consideration of biodiversity and ecosystems in strategy and business model
E4-2		Policies related to biodiversity and ecosystems
E4-3		Actions and resources related to biodiversity and ecosystems
E4-4		Targets related to biodiversity and ecosystems

ESRS E5 – Resource use and circular economy

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
E5-1		Policies related to resource use and circular economy
E5-2		Actions and resources related to resource use and circular economy
E5-3		Targets related to resource use and circular economy
E5-4		Resource inflows
E5-5		Resource outflow

Innovation, research, and development

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
I,R&D-1		Policies related to innovation, research, and development
I,R&D-2		Actions and resources related to innovation, research, and development
I,R&D-3		Targets related to innovation, research, and development
I,R&D-4		Metrics related to innovation, research, and development

Social Information

ESRS S1 – Own workforce

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
S1-1		Policies related to own workforce
S1-2		Processes for engaging with own workers and workers’ representatives about impacts
S1-3		Processes to remediate negative impacts and channels for own workers to raise concerns
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
S1-5		Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
S1-6		Characteristics of the undertaking’s employees
S1-8		Collective bargaining coverage and social dialogue
S1-9		Diversity metrics
S1-10		Adequate wages
S1-14		health & safety metrics
S1-16		Compensation metrics (pay gap and total compensation)
S1-17		Incidents, complaints, and severe human rights impacts

ESRS S2 – Workers in the value chain

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
S2-1		Policies related to value chain workers
S2-2		Processes for engaging with value chain workers about impacts
S2-3		Processes to remediate negative impacts and channels for value chain workers to raise concerns
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 actions
S2-5		Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

ESRS S3 – Affected communities

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
S3-1		Policies related to affected communities
S3-2		Processes for engaging with affected communities about impacts
S3-3		Processes to remediate negative impacts and channels for affected communities to raise concerns
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
S3-5		Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Governance Information

ESRS G1 – Business conduct

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
G1-1		Corporate culture and business conduct policies and corporate culture
G1-2		Management of relationships with suppliers
G1-3		Prevention and detection of corruption and bribery
G1-4		Confirmed incidents of corruption or bribery

Taxes

Disclosure requirement		Name with reference
SBM-3		Material impacts, risks, and opportunities and their interaction with strategy and business model
TAX-1		Policies related to taxes
TAX-2		Metrics related to taxes