IRO-2 – Disclosure requirements in ESRS covered by the undertaking’s sustainability report
The contents of this sustainability report were identified on the basis of the double materiality analysis. The exact procedure for the double materiality assessment can be found in the section IRO‑1. The selection of datapoints was based on the results of the materiality assessment. Based on this, a relevance analysis of the individual datapoints was carried out with the involvement of the respective departments. The materiality and applicability of individual datapoints was evaluated with regard to the gradual introduction of disclosure requirements. In addition, these were supplemented by company-specific datapoints on the topic of “Innovation, Research & Development” and the additional disclosure “Taxes”.
The following table lists all disclosure requirements (including page references) disclosed in the sustainability report:
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 | |
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BP-1 |
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BP-2 |
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GOV-1 |
The role of the administrative, management, and supervisory bodies |
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GOV-1 – G1 |
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GOV-2 |
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GOV-3 |
Integration of sustainability-related performance in incentive schemes |
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GOV-3 – E1 |
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GOV-4 |
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GOV-5 |
Risk management and internal controls over sustainability reporting |
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SBM-1 |
Strategy, business model, and value chain (Transitional provision for SBM-1 40 b, c used) |
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SBM-2 |
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SBM-2 – S1 |
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SBM-2 – S2 |
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SBM-2 – S3 |
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SBM-3 |
Material impacts, risks, and opportunities and their interaction with strategy and business model (Transitional provision for SBM-3 48 e used) |
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SBM-3 – E1 |
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SBM-3 – E4 |
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SBM-3 – S1 |
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SBM-3 – S2 |
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SBM-3 – S3 |
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|
IRO-1 |
Description of the process to identify and assess material impacts, risks, and opportunities |
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IRO-1 – E1 |
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IRO-1 – E2 |
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IRO-1 – E3 |
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IRO-1 – E4 |
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IRO-1 – E5 |
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|
IRO-1 – G1 |
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IRO-2 |
Disclosure requirements in ESRS covered by the undertaking’s sustainability report |
Environmental Information
| Disclosure requirement | Name with reference | |
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Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (EU Taxonomy Regulation) |
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ESRS E1 – Climate change
| Disclosure requirement | Name with reference | |
|
SBM-3 |
Material impacts, risks, and opportunities and their interaction with strategy and business model |
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E1-1 |
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E1-2 |
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|
E1-3 |
Actions and resources in relation to climate change policies |
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E1-4 |
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E1-5 |
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|
E1-6 |
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|
E1-9 |
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities (Transitional provision under ESRS used) |
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 |
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E2-2 |
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|
E2-3 |
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|
E2-4 |
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 |
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E3-2 |
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E3-3 |
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E3-4 |
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 |
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E4-1 |
Transition plan and consideration of biodiversity and ecosystems in strategy and business model |
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|
E4-2 |
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E4-3 |
Actions and resources related to biodiversity and ecosystems |
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|
E4-4 |
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 |
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|
E5-2 |
Actions and resources related to resource use and circular economy |
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|
E5-3 |
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|
E5-4 |
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|
E5-5 |
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 |
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|
I, R&D-2 |
Actions and resources related to innovation, research, and development |
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I, R&D-3 |
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|
I, R&D-4 |
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 |
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|
S1-1 |
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|
S1-2 |
Processes for engaging with own workers and workers’ representatives about impacts |
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S1-3 |
Processes to remediate negative impacts and channels for own workers to raise concerns |
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|
S1-4 |
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|
S1-5 |
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|
S1-6 |
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|
S1-7 |
Characteristics of non-employee workers in the undertaking’s own workforce (Transitional provision under ESRS used) |
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S1-8 |
Collective bargaining coverage and social dialogue (Transitional provision under ESRS used) |
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|
S1-9 |
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S1-10 |
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S1-12 |
Persons with disabilities (Transitional provision under ESRS used) |
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S1-13 |
Training and skills development metrics (Transitional provision under ESRS used) |
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|
S1-14 |
Health & safety metrics (Transitional provision under ESRS used) |
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|
S1-15 |
Work-life balance (Transitional provision under ESRS used) |
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|
S1-16 |
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|
S1-17 |
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 |
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|
S2-2 |
Processes for engaging with value chain workers about impacts |
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|
S2-3 |
Processes to remediate negative impacts and channels for value chain workers to raise concerns |
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|
S2-4 |
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|
S2-5 |
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 |
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|
S3-2 |
Processes for engaging with affected communities about impacts |
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|
S3-3 |
Processes to remediate negative impacts and channels for affected communities to raise concerns |
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|
S3-4 |
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|
S3-5 |
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 |
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|
G1-2 |
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|
G1-3 |
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|
G1-4 |
| Disclosure requirement | Name with reference | |
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 |
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Commission Delegated Regulation (EU) 2020/18165, Annex II |
|
Material |
The role of the administrative, management, and supervisory bodies |
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|
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 |
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|
ESRS 2 GOV-4 |
Statement on due diligence paragraph 30 |
Indicator number 10 Table #3 of Annex 1 |
|
|
|
Material |
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|
ESRS 2 SBM-1 |
Involvement in activities related to fossil fuel activities paragraph 40 (d) i |
Indicator 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. |
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|
ESRS 2 SBM-1 |
Involvement in activities related to chemical production paragraph 40 (d) ii |
Indicator number 9 Table #1 of Annex 2 |
|
Commission Delegated Regulation (EU) 2020/1816, Annex II |
|
Immaterial |
n. a. |
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|
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) |
|
Immaterial |
n. a. |
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|
ESRS 2 SBM-1 |
Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv |
|
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Delegated Regulation (EU) 2020/1818, Article 12(1) |
|
Immaterial |
n. a. |
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|
ESRS E1-1 |
Transition plan to reach climate neutrality by 2050 paragraph 14 |
|
|
|
Regulation (EU) 2021/1119 Article 2(1) |
Material |
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|
ESRS E1-1 |
Undertakings excluded from Paris-aligned Benchmarks paragraph 16 (g) |
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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, emissions and residual maturity |
Delegated Regulation (EU) 2020/1818, Article 12.1 (d) to (g), and Article 12.2 |
|
Material |
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|
ESRS E1-4 |
GHG emission reduction targets paragraph 34 |
Indicator number 4 Table #1 of Annex 2 |
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 6 |
|
Material |
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|
ESRS E1-5 |
Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38 |
Indicator number 5 Table #1 of Annex 1 and Indicator number 5 Table #1 of Annex 2 |
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|
Material |
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|
ESRS E1-5 |
Energy consumption and mix paragraph 37 |
Indicator number 5 Table #1 of Annex 1 |
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|
Material |
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|
ESRS E1-5 |
Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43 |
Indicator number 6 Table #1 of Annex 1 |
|
|
|
Material |
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|
ESRS E1-6 |
Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44 |
Indicators 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, emissions and residual maturity |
Delegation Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1) |
|
Material |
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|
ESRS E1-6 |
Gross GHG emissions intensity paragraphs 53 to 55 |
Indicator number 3 Table #1 of 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 |
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|
ESRS E1-7 |
GHG removals and carbon credits paragraph 56 |
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|
|
Regulation (EU) 2021/1119 Article 2(1) |
Immaterial |
n. a. |
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|
ESRS E1-9 |
Exposure of the benchmark portfolio to climate-related physical risks paragraph 66 |
|
|
Delegated Regulation (EU) 2020/1818, Annex II |
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Material (Transitional provision) |
n. a. |
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|
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 |
|
|
Material (Transitional provision) |
n. a. |
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|
ESRS E1-9 |
Breakdown of the carrying value of its real estate assets by energy-efficiency classes, paragraph 67 (c) |
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Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 paragraph 34; Template 2: Banking book – Climate change transition risk: loans |
|
|
Material (Transitional provision) |
n. a. |
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|
ESRS E1-9 |
Degree of exposure of the portfolio to climate-related opportunities paragraph 69 |
|
|
Commission Delegated Regulation (EU) 2020/1818, Annex II |
|
Material (Transitional provision) |
n. a. |
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|
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 |
|
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|
Material |
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|
ESRS E3-1 |
Water and marine resources paragraph 9 |
Indicator number 7 Table #1 of Annex 2 |
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|
Material |
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|
ESRS E3-1 |
Dedicated policy paragraph 13 |
Indicator number 8 Table #1 of Annex 2 |
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|
|
Material |
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|
ESRS E3-1 |
Sustainable oceans and seas paragraph 14 |
Indicator number 12 Table #1 of Annex 2 |
|
|
|
Immaterial |
n. a. |
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|
ESRS E3-4 |
Total water recycled and reused paragraph 28 (c) |
Indicator number 6.2 Table #1 of Annex 2 |
|
|
|
Material |
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|
ESRS E3-4 |
Total water consumption in m3 per net revenue on own operations paragraph 29 |
Indicator number 6.1 Table #1 of Annex 2 |
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|
Material |
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|
ESRS 2 – IRO-1 – E4 |
paragraph 16(a) i |
Indicator number 7 Table #1 of Annex 1 |
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|
Material |
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|
ESRS 2 – IRO-1 – E4 |
paragraph 16 (b) |
Indicator number 10 Table #1 of Annex 2 |
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|
|
Material |
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|
ESRS 2 – IRO-1 – E4 |
paragraph 16 (c) |
Indicator number 14 Table #1 of Annex 2 |
|
|
|
Material |
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|
ESRS E4-2 |
Sustainable land/agriculture practices or policies paragraph 24(b) |
Indicator number 11 Table #1 of Annex 2 |
|
|
|
Immaterial |
n. a. |
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|
ESRS E4-2 |
Sustainable oceans/seas practices or policies paragraph 24 (c) |
Indicator number 12 Table #1 of Annex 2 |
|
|
|
Immaterial |
n. a. |
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|
ESRS E4-2 |
Policies to address deforestation paragraph 24 (d) |
Indicator number 15 Table #1 of Annex 2 |
|
|
|
Immaterial |
n. a. |
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|
ESRS E5-5 |
Non-recycled waste paragraph 37 (d) |
Indicator number 13 Table #1 of Annex 2 |
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|
|
Material |
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|
ESRS E5-5 |
Hazardous waste and radioactive waste paragraph 39 |
Indicator number 9 Table #1 of Annex 1 |
|
|
|
Material |
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|
ESRS 2 SBM-3 – S1 |
Risk of incidents of forced labour paragraph 14 (f) |
Indicator number 13 Table #1 of Annex 3 |
|
|
|
Material |
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|
ESRS 2 SBM-3 – S1 |
Risk of incidents of child labour paragraph 14 (g) |
Indicator number 12 Table #1 of Annex 3 |
|
|
|
Material |
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|
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 |
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|
ESRS S1-1 |
Due diligence policies on issues addressed by the fundamental International Labour Organisation Conventions 1 to 8, paragraph 21 |
|
|
Commission Delegated Regulation (EU) 2020/1816, Annex II |
|
Material |
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|
ESRS S1-1 |
Processes and measures for preventing trafficking in human beings paragraph 22 |
Indicator number 11 Table #1 of Annex 3 |
|
|
|
Material |
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|
ESRS S1-1 |
Workplace accident prevention policy or management system paragraph 23 |
Indicator number 1 Table #1 of Annex 3 |
|
|
|
Material |
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|
ESRS S1-3 |
Grievance/complaints handling mechanisms paragraph 32 (c) |
Indicator number 5 Table #1 of Annex 3 |
|
|
|
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 #1 of Annex 3 |
|
Commission Delegated Regulation (EU) 2020/1816, Annex II |
|
Material (partially transitional provision) |
||||||||
|
ESRS S1-14 |
Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e) |
Indicator number 3 Table #1 of Annex 3 |
|
|
|
Material (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 |
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|
ESRS S1-16 |
Excessive CEO pay ratio paragraph 97 (b) |
Indicator number 8 Table #1 of Annex 3 |
|
|
|
Material |
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|
ESRS S1-17 |
Incidents of discrimination paragraph 103 (a) |
Indicator number 7 Table #1 of Annex 3 |
|
|
|
Material |
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|
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 |
|
Material |
||||||||
|
ESRS 2 SBM-3 – S2 |
Significant risk of child labour or forced labour in the value chain paragraph 11 (b) |
Indicators number 12 and 13 Table #3 of Annex 1 |
|
|
|
Material |
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|
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 |
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|
ESRS S2-1 |
Policies related to value chain workers paragraph 18 |
Indicators number 11 and 4 Table #3 of Annex 1 |
|
|
|
Material |
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|
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 |
|
Material |
||||||||
|
ESRS S2-1 |
Due diligence policies on issues addressed by the fundamental International Labour Organisation Conventions 1 to 8, paragraph 19 |
|
|
Commission Delegated Regulation (EU) 2020/1816, Annex II |
|
Material |
||||||||
|
ESRS S2-4 |
Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36 |
Indicator number 14 Table #1 of Annex 3 |
|
|
|
Material |
||||||||
|
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 |
|
|
|
Immaterial |
n. a. |
|||||||
|
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 of Annex 1 |
|
Delegated Regulation (EU) 2020/1816, Annex II |
|
Material |
||||||||
|
ESRS S3-4 |
Human rights issues and incidents paragraph 36 |
Indicator number 14 Table #1 of Annex 3 |
|
|
|
Immaterial |
n. a. |
|||||||
|
ESRS S4-1 |
Policies related to consumers and end-users paragraph 16 |
Indicator number 9 Table #3 of Annex 1 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 |
|
Immaterial |
n. a. |
|||||||
|
ESRS S4-4 |
Human rights issues and incidents paragraph 35 |
Indicator number 14 Table #1 of Annex 3 |
|
|
|
Immaterial |
n. a. |
|||||||
|
ESRS G1-1 |
United Nations Convention against Corruption paragraph 10 (b) |
Indicator number 15 Table #1 of Annex 3 |
|
|
|
Material |
|
|||||||
|
ESRS G1-1 |
Protection of whistleblowers paragraph 10 (b) |
Indicator number 6 Table #1 of Annex 3 |
|
|
|
Material |
|
|||||||
|
ESRS G1-4 |
Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a) |
Indicator number 17 Table #1 of Annex 3 |
|
Commission Delegated Regulation (EU) 2020/1816, Annex II |
|
Material |
||||||||
|
ESRS G1-4 |
Standards of anti-corruption and anti-bribery paragraph 24 (b) |
Indicator number 16 Table #1 of Annex 3 |
|
|
|
Material |
| 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 (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). |