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Name of your organisation:([ID2])
Name of the public authority:([ID3])
Is your organisation included in the Transparency Register? (If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)(transparency-register)
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Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Materiality/Relevance ([ID11])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Usefulness ([ID12])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Comparability ([ID13])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Avoiding undue administrative burden ([ID26])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Comprehensiveness ([ID27])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Fairness and balance ([ID28])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Understandability ([ID29])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Reliability ([ID30])
Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES? : Other ([ID31])
Please specify what other aspect of disclosure of non-financial information should be addressed by the GUIDELINES:([ID14])
Q2. Who should be considered in your opinion the main audience of the non-financial statement?([ID15])
Please specify who else should be considered in your opinion the main audience of the non-financial statement:([ID16])
Q2.1 Could you please provide a brief explanation on your answer regarding who should be considered the main audience of the non-financial statement?([ID17])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Useful for the management/directors of the company ([ID40])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Relevant for shareholders or investors’ decision-making ([ID41])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Relevant for stakeholders in general ([ID42])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Necessary to understand the impacts of the company’s activity ([ID43])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Necessary to understand the company’s development, performance and position ([ID44])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Necessary to understand how the company manages non-financial risks ([ID45])
Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement? : Other ([ID46])
Please specify what other features make a piece of information relevant (or material) for the purposes of the non-financial statement:([ID76])
Q3.1 Could you please provide a brief explanation on your answer regarding the features which make a piece of information relevant (or material) for the purposes of the non-financial statement?([ID38])
Q4. Do you think that the GUIDELINES will be more useful for companies and users if they set out general principles and key ideas or if they put forward solutions in a detailed manner, including on specific sectoral issues? : Please, indicate on a scale from 1 to 5 (1 geared towards general principles, 5 high level of detail/prescription) ([ID51])
Q4.1 Could you please provide a brief explanation on your answer regarding whether the GUIDELINES will be more useful for companies and users if they set out general principles and key ideas or if they prescribe solutions in a detailed manner, including on specific sectoral issues?([ID52])
a. Business model:([ID57])
b. Policies:([ID58])
c. Due diligence process:([ID59])
d. Business relationships:([ID60])
e. Key performance indicators –KPIs:([ID61])
f. Outcome of policies:([ID62])
g. Principal risks:([ID63])
h. Impact of the activity:([ID64])
i. Adverse impacts:([ID65])
j. Information omitted in exceptional cases where disclosure would be seriously prejudicial:([ID66])
Q6. How do you think that the GUIDELINES should approach the disclosure of key performance indicators (KPIs)? : The GUIDELINES should highlight key principles on how to disclose relevant KPIs and complementariness with narrative and/or financial information as applicable ([ID71])
Q6. How do you think that the GUIDELINES should approach the disclosure of key performance indicators (KPIs)? : The GUIDELINES should make reference to KPIs proposed by other frameworks where addressing concrete matters or issues ([ID72])
Q6. How do you think that the GUIDELINES should approach the disclosure of key performance indicators (KPIs)? : The GUIDELINES should include a comprehensive list of KPIs, general and sectoral ([ID70])
Q6. How do you think that the GUIDELINES should approach the disclosure of key performance indicators (KPIs)? : The GUIDELINES should provide flexibility for companies to exercise judgement in deciding what KPIs should be included in their disclosures ([ID74])
Q6. How do you think that the GUIDELINES should approach the disclosure of key performance indicators (KPIs)? : Other ([ID75])
Please specify what other approach you would advocate:([ID73])
Q6.1 Could you please provide a brief explanation on your answer regarding how you think the GUIDELINES should approach the disclosure of key performance indicators (KPIs)?([ID78])
Q7. Do you think that the GUIDELINES should include guidance on specific sectoral issues such as responsible supply chain management of conflict minerals? : Please, indicate on a scale from 1 to 5 (1 geared towards general principles, 5 high level of detail/prescription) ([ID110])
Q7.1 Could you please provide a brief explanation on your answer regarding whether the GUIDELINES should include guidance on specific sectoral issues such as responsible supply chain management of conflict minerals?([ID111])
Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)? : The GUIDELINES should include detailed solutions and be an exhaustive document in a way that could make unnecessary for companies the use of other guidelines ([ID87])
Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)? : The GUIDELINES should be complementary to other frameworks ([ID88])
Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)? : The GUIDELINES should make reference to other frameworks where addressing concrete matters or specific issues ([ID89])
Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)? : The GUIDELINES should get general inspiration from other frameworks ([ID90])
Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)? : The GUIDELINES should explain how content produced in the context of other frameworks could be used in the non-financial statement ([ID91])
Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)? : Other ([ID92])
Please specify what other approach you would advocate:([ID94])
Q8.1 Could you please provide a brief explanation on your answer regarding how you think the GUIDELINES should relate to existing national, international or other EU-based frameworks?([ID95])
Q9. Do you think that when preparing the GUIDELINES only the companies included in the scope of the DIRECTIVE should be considered, or that the interests, characteristics and/or requirements of other companies that prepare management reports should be taken into account as well?([ID86])
Q9.1 Accordingly, do you think that the content of the guidelines should be different according to the targeted companies? Could you please provide a brief explanation?([ID100])
Q10. Does your company disclose annually relevant non-financial information?([ID96])
If your company does disclose annually relevant non-financial information, does it use any existing reporting framework(s)?([ID97])
If your company does use any existing reporting framework(s), could you please indicate which one(s)?([ID98])
Q11. Should the GUIDELINES provide more clarity on what companies should disclose as regards their board diversity?([ID101])
Q11.1 Could you please provide a brief explanation on your answer regarding whether the GUIDELINES should provide more clarity on what companies should disclose as regards their board diversity policy?([ID102])
Please, upload, as needed, any relevant document or information that you consider useful for the purposes of this consultation. In doing so, you are invited to take into account the content of recital 7 of the DIRECTIVE: “Where undertakings are required to prepare a non-financial statement, that statement should contain, as regards environmental matters, details of the current and foreseeable impacts of the undertaking’s operations on the environment, and, as appropriate, on health and safety, the use of renewable and/or non-renewable energy, greenhouse gas emissions, water use and air pollution. As regards social and employee-related matters, the information provided in the statement may concern the actions taken to ensure gender equality, implementation of fundamental conventions of the International Labour Organisation, working conditions, social dialogue, respect for the right of workers to be informed and consulted, respect for trade union rights, health and safety at work and the dialogue with local communities, and/or the actions taken to ensure the protection and the development of those communities. With regard to human rights, anti-corruption and bribery, the non-financial statement could include information on the prevention of human rights abuses and/or on instruments in place to fight corruption and bribery”.(file-upload)
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Are you replying as:
First name and last name:
Name of your organisation:
Name of the public authority:
Is your organisation included in the Transparency Register?
(If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)
If so, please indicate your Register ID number:
Type of organisation:
Please specify the type of organisation:
Type of public authority
Please specify the type of public authority:
Where are you based and/or where do you carry out your activity?
Please specify your country:
Field of activity or sector (if applicable):
Please specify your activity field(s) or sector(s):
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
(see specific privacy statement PDF)

Q1. What aspects of disclosure of non-financial information do you think that should be addressed by the GUIDELINES?

Materiality/Relevance
Usefulness
Comparability
Avoiding undue administrative burden
Comprehensiveness
Fairness and balance
Understandability
Reliability
Other

Please specify what other aspect of disclosure of non-financial information should be addressed by the GUIDELINES:

Q2. Who should be considered in your opinion the main audience of the non-financial statement?

Please specify who else should be considered in your opinion the main audience of the non-financial statement:

Q2.1 Could you please provide a brief explanation on your answer regarding who should be considered the main audience of the non-financial statement?

Q3. In your opinion, what features make a piece of information relevant (or material) for the purposes of the non-financial statement?

Useful for the management/directors of the company
Relevant for shareholders or investors’ decision-making
Relevant for stakeholders in general
Necessary to understand the impacts of the company’s activity
Necessary to understand the company’s development, performance and position
Necessary to understand how the company manages non-financial risks
Other

Please specify what other features make a piece of information relevant (or material) for the purposes of the non-financial statement:

Q3.1 Could you please provide a brief explanation on your answer regarding the features which make a piece of information relevant (or material) for the purposes of the non-financial statement?

Q4. Do you think that the GUIDELINES will be more useful for companies and users if they set out general principles and key ideas or if they put forward solutions in a detailed manner, including on specific sectoral issues?

Please, indicate on a scale from 1 to 5
(1 geared towards general principles, 5 high level of detail/prescription)

Q4.1 Could you please provide a brief explanation on your answer regarding whether the GUIDELINES will be more useful for companies and users if they set out general principles and key ideas or if they prescribe solutions in a detailed manner, including on specific sectoral issues?

a. Business model:

b. Policies:

c. Due diligence process:

d. Business relationships:

e. Key performance indicators –KPIs:

f. Outcome of policies:

g. Principal risks:

h. Impact of the activity:

i. Adverse impacts:

j. Information omitted in exceptional cases where disclosure would be seriously prejudicial:

Q6. How do you think that the GUIDELINES should approach the disclosure of key performance indicators (KPIs)?

The GUIDELINES should highlight key principles on how to disclose relevant KPIs and complementariness with narrative and/or financial information as applicable
The GUIDELINES should make reference to KPIs proposed by other frameworks where addressing concrete matters or issues
The GUIDELINES should include a comprehensive list of KPIs, general and sectoral
The GUIDELINES should provide flexibility for companies to exercise judgement in deciding what KPIs should be included in their disclosures
Other

Please specify what other approach you would advocate:

Q6.1 Could you please provide a brief explanation on your answer regarding how you think the GUIDELINES should approach the disclosure of key performance indicators (KPIs)?

Q7. Do you think that the GUIDELINES should include guidance on specific sectoral issues such as responsible supply chain management of conflict minerals?

Please, indicate on a scale from 1 to 5
(1 geared towards general principles, 5 high level of detail/prescription)

Q7.1 Could you please provide a brief explanation on your answer regarding whether the GUIDELINES should include guidance on specific sectoral issues such as responsible supply chain management of conflict minerals?

Q8. How do you think that the GUIDELINES should relate to existing national, international or other EU-based frameworks (such as UN Global Compact, the UN Guiding Principles on Business and Human Rights, OECD guidelines for multinational enterprises, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy, EMAS, etc.)?

The GUIDELINES should include detailed solutions and be an exhaustive document in a way that could make unnecessary for companies the use of other guidelines
The GUIDELINES should be complementary to other frameworks
The GUIDELINES should make reference to other frameworks where addressing concrete matters or specific issues
The GUIDELINES should get general inspiration from other frameworks
The GUIDELINES should explain how content produced in the context of other frameworks could be used in the non-financial statement
Other

Please specify what other approach you would advocate:

Q8.1 Could you please provide a brief explanation on your answer regarding how you think the GUIDELINES should relate to existing national, international or other EU-based frameworks?

Q9. Do you think that when preparing the GUIDELINES only the companies included in the scope of the DIRECTIVE should be considered, or that the interests, characteristics and/or requirements of other companies that prepare management reports should be taken into account as well?

Q9.1 Accordingly, do you think that the content of the guidelines should be different according to the targeted companies? Could you please provide a brief explanation?

Q10. Does your company disclose annually relevant non-financial information?

If your company does disclose annually relevant non-financial information, does it use any existing reporting framework(s)?

If your company does use any existing reporting framework(s), could you please indicate which one(s)?

Q11. Should the GUIDELINES provide more clarity on what companies should disclose as regards their board diversity?

Q11.1 Could you please provide a brief explanation on your answer regarding whether the GUIDELINES should provide more clarity on what companies should disclose as regards their board diversity policy?

Please, upload, as needed, any relevant document or information that you consider useful for the purposes of this consultation.

In doing so, you are invited to take into account the content of recital 7 of the DIRECTIVE:

Where undertakings are required to prepare a non-financial statement, that statement should contain, as regards environmental matters, details of the current and foreseeable impacts of the undertaking’s operations on the environment, and, as appropriate, on health and safety, the use of renewable and/or non-renewable energy, greenhouse gas emissions, water use and air pollution. As regards social and employee-related matters, the information provided in the statement may concern the actions taken to ensure gender equality, implementation of fundamental conventions of the International Labour Organisation, working conditions, social dialogue, respect for the right of workers to be informed and consulted, respect for trade union rights, health and safety at work and the dialogue with local communities, and/or the actions taken to ensure the protection and the development of those communities. With regard to human rights, anti-corruption and bribery, the non-financial statement could include information on the prevention of human rights abuses and/or on instruments in place to fight corruption and bribery”.

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