List of disclosures
Disclosure requirements in ESRS covered by the undertaking’s sustainability statement
List of ESRS disclosure requirements
| Disclosure requirement | Page |
| BP-1 General basis for preparation of sustainability statements | 81-82 |
| BP-2 Disclosure in relation to specific circumstances | 82-83 |
| GOV-1 The role of the administrative, management and supervisory bodies | 83-85 |
| GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies | 83-85 |
| GOV-3 Integration of sustainability-related performance in incentive schemes | 85 |
| GOV-4 Statement on due diligence | 85-86 |
| GOV-5 Risk management and internal controls over sustainability reporting | 86-87 |
| SBM-1 Strategy, business model and value chain | 87-88 |
| SBM-2 Interests and views of stakeholders | 88-89 |
| SBM-3 Material impacts, risks, and opportunities and their interaction with strategy and business model | 88, 93-96, 109, 112-113, 121-122, 133-134, 140-141, 144, 148-149 |
| IRO-1 Process to identify and assess material impacts, risks and opportunities | 90-91 |
| IRO-2 Disclosure requirements in ESRS covered by the undertaking’s sustainability statement | 91-92, 154-158 |
| E1-1 Transition plan for climate change mitigation | 96-99 |
| E1-2 Policies related to climate change mitigation | 99-100 |
| E1-3 Actions and resources in relation to climate change policies | 100-102 |
| E1-4 Targets relating to climate change mitigation | 102-104 |
| E1-5 Energy consumption and mix | 105 |
| E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions | 105-107 |
| E1-7 GHG removals and GHG mitigation projects financed through carbon credits | 108 |
| E1-8 Internal carbon pricing | 108 |
| EU taxonomy report | 118-119 |
| E2-1 Policies related to pollution | 109-110 |
| E2-2 Actions and resources related to pollution | 110 |
| E2-3 Targets related to pollution | 111 |
| E2-5 Substances of concern and substances of very high concern | 111 |
| E5-1 Policies related to resource use and circular economy | 113 |
| E5-2 Actions and resources related to resource use and circular economy | 114-115 |
| E5-3 Targets related to resource use and circular economy | 116 |
| E5-4 Resource inflows | 116 |
| E5-5 Resource outflows | 116-117 |
| S1-1 Policies for own workforce | 122-123 |
| S1-2 Processes for engaging with own workforce and workers’ representatives about impacts | 123 |
| S1-3 Processes to remediate negative impacts and channels for own workforce to raise concerns | 124 |
| S1-4 Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions | 124-130 |
| S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 126, 128, 130 |
| S1-6 Characteristics of the undertaking’s employees | 130-131 |
| S1-8 Collective bargaining | 131 |
| S1-9 Diversity metrics | 128-129 |
| S1-10 Adequate wages | 132 |
| S1-14 Health and Safety metrics | 127 |
| S1-16 Renumeration metrics | 132 |
| S1-17 Incidents, complaints and severe human rights impacts | 132 |
| S2-1 Policies related to value chain workers | 134-135 |
| S2-2 Processes for engaging with value chain workers about impacts | 135 |
| S2-3 Processes to remediate negative impacts and channels for value chain workers to raise concerns | 136 |
| 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 | 136-138 |
| S2-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 138 |
| S3-1 Policies related to affected communities | 141 |
| S3-2 Processes for engaging with affected communities about impacts | 141 |
| S3-3 Processes for engaging with affected communities about impacts | 142 |
| 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 | 142 |
| S3-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 143 |
| S4-1 Policies related to consumers and end-users | 145 |
| S4-2 Processes for engaging with consumers and end-users about impacts | 145 |
| S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns | 145-146 |
| 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 | 146-147 |
| S4-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | 147 |
| G1-1 Business conduct policies and corporate culture | 149-151 |
| G1-3 Prevention and detection of corruption and bribery | 151-152 |
| G1-4 Incidents of corruption or bribery | 153 |
List of data points in cross-cutting and topical standards that derive from other EU legislation
The table below illustrates the datapoints in each ESRS that derive from other EU legislation, indicating where they can be found in the sustainability statement and whether they are assessed as material or not material.
| Disclosure Requirement and related datapoint | SFDR | Pillar 3 | Benchmark Regulation | EU Climate Law | Page / Not material |
| ESRS 2 GOV-1 Board's gender diversity paragraph 21 (d) | x | x | 60 | ||
| ESRS 2 GOV-1 Percentage of board members who are independent paragraph 21 (e) |
x | 60 | |||
| ESRS 2 GOV-4 Statement on due diligence paragraph 30 | x | 85-86 | |||
| ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities paragraph 40 (d) i | x | x | x | 99 | |
| ESRS 2 SBM-1 Involvement in activities related to chemical production paragraph 40 (d) ii | x | x | Not material | ||
| ESRS 2 SBM-1 Involvement in activities related to controversial weapons paragraph 40 (d) iii | x | x | Not material | ||
| ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv | x | Not material | |||
| ESRS E1-1 Transition plan to reach climate neutrality by 2050 paragraph 14 | x | 96-99 | |||
| ESRS E1-1 Undertakings excluded from Paris-aligned Benchmarks paragraph 16 (g) | x | x | 99 | ||
| ESRS E1-4 GHG emission reduction targets paragraph 34 | x | x | x | 102-104 | |
| ESRS E1-5 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38 | x | 105 | |||
| ESRS E1-5 Energy consumption and mix paragraph 37 | x | 105 | |||
| ESRS E1-5 Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43 | x | 105 | |||
| ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44 | x | x | x | 105 | |
| ESRS E1-6 Gross GHG emissions intensity paragraphs 53 to 55 | x | x | x | 106 | |
| ESRS E1-7 GHG removals and carbon credits paragraph 56 | x | 108 | |||
| ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66 | x | Not material | |||
| ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a) ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c). | x | Not material | |||
| ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c). | x | Phase-in | |||
| ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69 | x | Phase-in | |||
| ESRS E2-4 Amount of each pollutant listed in Annex II of the EPRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil, paragraph 28 | x | Not material | |||
| ESRS E3-1 Water and marine resources paragraph 9 | x | Not material | |||
| ESRS E3-1 Dedicated policy paragraph 13 | x | Not material | |||
| ESRS E3-1 Sustainable oceans and seas paragraph 14 | x | Not material | |||
| ESRS E3-4 Total water recycled and reused paragraph 28 (c) | x | Not material | |||
| ESRS E3-4 Total water consumption in m3 per net revenue on own operations paragraph 29 | x | Not material | |||
| ESRS 2- IRO 1 - E4 paragraph 16 (a) i | x | Not material | |||
| ESRS 2- IRO 1 - E4 paragraph 16 (b) | x | Not material | |||
| ESRS 2- IRO 1 - E4 paragraph 16 (c) | x | Not material | |||
| ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) | x | Not material | |||
| ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) | x | Not material | |||
| ESRS E4-2 Policies to address Deforestation paragraph 24 (d) | x | Not material | |||
| ESRS E5-5 Non-recycled waste paragraph 37 (d) | x | 117 | |||
| ESRS E5-5 Hazardous waste and radioactive waste paragraph 39 | x | 117 | |||
| ESRS 2- SBM3 - S1 Risk of incidents of forced labour paragraph 14 (f) | x | 122 | |||
| ESRS 2- SBM3 - S1 Risk of incidents of child labour paragraph 14 (g) | x | 122 | |||
| ESRS S1-1 Human rights policy Commitments paragraph 20 | x | 122 | |||
| ESRS S1-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 21 | x | 122 | |||
| ESRS S1-1 processes and measures for preventing trafficking in human beings paragraph 22 | x | 122 | |||
| ESRS S1-1 workplace accident prevention policy or management system paragraph 23 | x | 122 | |||
| ESRS S1-3 grievance/ complaints handling mechanisms paragraph 32 (c) | x | 124 | |||
| ESRS S1-14 Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c) | x | x | 127 | ||
| ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e) | x | 127 | |||
| ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a) | x | x | 132 | ||
| ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b) | x | 132 | |||
| ESRS S1-17 Incidents of Discrimination paragraph 103 (a) | x | 132 | |||
| ESRS S1-17 Non-respect of UNGPs on Business and Human Rights and OECD paragraph 104 (a) | x | x | 132 | ||
| ESRS 2- SBM3 S2 Significant risk of child labour or forced labour in the value chain paragraph 11 (b) | x | 133-134 | |||
| ESRS S2-1 Human rights policy commitments paragraph 17 | x | 134-135 | |||
| ESRS S2-1 Policies related to value chain workers paragraph 18 | x | 134-135 | |||
| ESRS S2-1 Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines paragraph 19 | x | x | 134-135 | ||
| ESRS S2-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19 | x | 134-135 | |||
| ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36 | x | 136 | |||
| ESRS S3-1 Human rights policy commitments paragraph 16 | x | 141 | |||
| ESRS S3-1 non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17 | x | x | 141 | ||
| ESRS S3-4 Human rights issues and incidents paragraph 36 | x | 142 | |||
| ESRS S4-1 Policies related to consumers and end-users paragraph 16 | x | 145 | |||
| ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17 | x | x | 145 | ||
| ESRS S4-4 Human rights issues and incidents paragraph 35 | x | 147 | |||
| ESRS G1-1 United Nations Convention against Corruption paragraph 10 (b) | x | Not material | |||
| ESRS G1-1 Protection of whistleblowers paragraph 10 (d) | x | Not material | |||
| ESRS G1-4 Fines for violation of anti-corruption and anti- bribery laws paragraph 24 (a) | x | x | 153 | ||
| ESRS G1-4 Standards of anti- corruption and anti- bribery paragraph 24 (b) | x | 153 |