EUSurvey     All public surveys   
Login | |
system message icon

Published Results: non-financial-report...

Export
For performance reasons you can only set a maximum of 3 filters
Are you replying as:(replying-as)
First name and last name:(organisation-identity-public)
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)
If so, please indicate your Register ID number:(id-transparency-register)
Type of organisation:(organisation-type)
Please specify the type of organisation:(specify-organisation-type)
Type of public authority(public-authority-type)
Please specify the type of public authority:(specify-public-authority-type)
Where are you based and/or where do you carry out your activity?(country)
Please specify your country:(specify-country)
Field of activity or sector (if applicable):(activity-field)
Please specify your activity field(s) or sector(s):(specify-activity-field)
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published? (see specific privacy statement )(contributions-publication)
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)
All Values
Apply Filter
a private individual
an organisation or a company
a public authority or an international organisation
All Values
Apply Filter
Academic institution
Company, SME, micro-enterprise, sole trader
Consultancy, law firm
Consumer organisation
Industry association
Media
Non-governmental organisation
Think tank
Trade union
Other
All Values
Apply Filter
International or European organisation
Regional or local authority
Government or Ministry
Regulatory authority, Supervisory authority or Central bank
Other public authority
All Values
Apply Filter
Austria
Belgium
Bulgaria
Croatia
Cyprus
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Iceland
Ireland
Italy
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Norway
Poland
Portugal
Romania
Slovakia
Slovenia
Spain
Sweden
Switzerland
The Netherlands
United Kingdom
Other country
All Values
Apply Filter
Accounting
Auditing
Rating agencies
Banking
Insurance
Reporting/Communication
Corporate Social Responsibipty/ Sustainabipty
Investment management (e.g. hedge funds, private equity funds, venture capital funds, money market funds, securities)
Other
Not apppcable
All Values
Apply Filter
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)
No, I do not want my response to be published
All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7

8

9
(most
important)

All Values
Apply Filter
The shareholders
The investment community in a broad sense
Users of information with an economic interest, such as suppliers, customers, employees, etc.
All users of information (including consumers, local communities, NGOs, etc.)
Other
All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1
(least
important)

2

3

4

5

6

7
(most
important)

All Values
Apply Filter

1

2

3

4

5

No opinion

All Values
Apply Filter

1
(best option)

2
(second preferred option)

All Values
Apply Filter

1
(best option)

2
(second preferred option)

All Values
Apply Filter

1
(best option)

2
(second preferred option)

All Values
Apply Filter

1
(best option)

2
(second preferred option)

All Values
Apply Filter

1
(best option)

2
(second preferred option)

All Values
Apply Filter

1

2

3

4

5

No opinion

All Values
Apply Filter

1
(least in line)

2

3

4

5

6
(most in line)

All Values
Apply Filter

1
(least in line)

2

3

4

5

6
(most in line)

All Values
Apply Filter

1
(least in line)

2

3

4

5

6
(most in line)

All Values
Apply Filter

1
(least in line)

2

3

4

5

6
(most in line)

All Values
Apply Filter

1
(least in line)

2

3

4

5

6
(most in line)

All Values
Apply Filter

1
(least in line)

2

3

4

5

6
(most in line)

All Values
Apply Filter
Specific to the requirements of the companies under scope of the DIRECTIVE
Consider all large companies
Consider all companies
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports
All Values
Apply Filter
Yes
No
Don’t know / no opinion / not relevant
All Values
Apply Filter
Yes
No
Don’t know / no opinion / not relevant
All Values
Apply Filter
Yes
No
Don’t know / no opinion / not relevant
an organisation or a company(organisation-replying-as)
 
Badai
 
Yes(yes-transparency-register)
555632318779-09
Other([ID14])
Political party
 
 
Austria([ID21])
 
Not apppcable([ID8])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
4
3
8
1 (least important)
5
7
6
9 (most important)
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
The civil society also has a legitimate interest in the information provided in the non-financial statements.
2
4
3
7 (most important)
5
6
 
 
For a non-financial statement, the focus should not be on the company's or the stakeholder's financial interests, neither directly nor indirectly. It should focus on the impact _of_ the company's activity rather than influences _on_ the company's activity.
4
Presciption certainly has advantages in terms of comparability and understandability of non-financial statements. However, we do understand that some flexibility may be required.
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)
 
1 (best option)
 
 
 
Selecting from a list of key performance indicators allows for higher comparability.
4
Some issues like this are quite important and there is a clear need for them to be communicated clearly.
4
3
6 (most in line)
5
2
1 (least in line)
While the guidelines should certainly be independent from any other frameworks on any level, it may be helpful to refer to other frameworks. At this point, we would like to add that we would prefer binding rules over non-binding guidelines.
Consider all companies([ID98])
Yes, to some extent. Different economic sectors would have quite different activities, which should be reflected in the guidelines.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
Board diversity is an important issue, which should be appropriately covered in non-financial statements and, hence, in the guidelines.
 
a private individual(public-replying-as)
Edison Tabra
 
 
 
 
 
 
 
 
Other country([ID53])
Peru
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)
7
8
6
5
3
4
2
 
 
The shareholders([ID16])
 
They put capital to work of company adn assume risks in case losts.
7 (most important)
6
4
3
2
1 (least important)
 
 
Information promotes good performance in companies.
5
It woul promote transparency and accountability in markets.
 
 
 
 
 
 
 
 
 
 
1 (best option)
2 (second preferred option)
 
 
 
 
It provides reliability on companies.
5
It provides reliability on companie and provides attention to stakeholders.
6 (most in line)
2
3
4
5
1 (least in line)
Guidelines must be reliable.
It i neceary to promote autoregulation in companies and markets.
Consider all large companies([ID97])
No.
 
 
 
Yes([ID96])
It goes in concordance to corporate governance of companies which promotes diversity in board of directors.
 
an organisation or a company(organisation-replying-as)
 
DNVGL Business Assurance
 
No(no-transparency-register)
 
Other([ID14])
auditing and certification body
 
 
Italy([ID36])
 
Auditing([ID6])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)
3
2
5
6
7
4
8
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
The audience should be extended to all potential stakeholders affected by the reporting organisation's operations, even if not linked by direct financial interest
4
5
6
3
2
7 (most important)
 
 
the report should be considered a complement to the financial report, showing how the company manage non-financial risks.
4
if the guidelines will stay at generic level (such as principles) there is the risk to provide unclear advice and as consequence there is the risk of different interpretations by the reporting organisations. allowing them to provide an unclear representation of the situation in case of bad performance
the guidelines should provide clear indication on how the reporting organization is organized to produce goods and services and make money, not only how much money is produced...
at least for the following topics should be required the disclosure of a policy: - environment - health and safety - labor issues - ethics
 
 
It would be good to provide indication to set a robust framework for KPIs, allowing also comparison among reporting organisations
 
this should be based on the materiality principle (applied by the single organization), rather than on pre-defined set of risks
 
 
It should be defined a very robust approach for allowing the reporting organization to omit information. "Lack of data or info" should not be a valid reason for omission.
2 (second preferred option)
1 (best option)
 
 
 
 
no comment
5
Even if based on the application of the materiality principle, the GUIDELINES should provide clear indications on how to include the main material sectoral issues. A supporting document is likely the best option to provide info around critical issues per sector.
6 (most in line)
5
4
2
3
1 (least in line)
no additional comment
especially for medium-small companies, the integration should aim to reduce the cost of reporting (one report should cover all the needs for non-financial disclosure)
Consider all companies([ID98])
NO, Guideline should be enough generic to be applied by all types of organizations.
Yes([ID96])
Yes([ID96])
GRI (G4)
Yes([ID96])
no comment
 
a private individual(public-replying-as)
Cristina de Anduaga
 
 
 
 
 
 
 
 
Spain([ID48])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8
3
4
6
5
2
7
9 (most important)
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
All the stakeholders should be taken into account when the Report is published. Depend on the topic that you are explaining, specific groups may be found as the most interested group and information will need to be developed based on this.
1 (least important)
6
7 (most important)
5
4
3
2
CSR compliance and economic benefits got when the building / Project is considered public benefit. With obligations were developed to comply with this.
Companies should understand that it has an influence in their stakeholders as well as stakeholders may influence in the results of the companies. Also because companies have a corporate responsibility with the environment (in a broad interpretation of the Word) and the most relevant information needs to be accesible to all the stakeholders (positive impact and negative impact of the company).
4
General ideas may do the process easier and, why not, more effective. However, rules or ideas needs to be more strict tan usual because the companies tend to focus on favorable information, using complicated formulations that doesn´t let understand the real situation.
Nature of the business; how they get the incomes; how the policies are defined (supply policies, HR policies, Environmental policies; Health and Safety policiy); how they connect with the environment and how they manage the impacts.
- Supply policies ( which criterias they use to select the suppliers, local suppliers rates; ethic codes, wich level of involvement they have with the supply chain, audits...) - HR policies (local rates, kind of contract, W/M rates, women in responsibility charges, staff turnover rate, H&S ..) - Non financial risk policy ( Reputation, corruption...) - Environmental policies
The different processes developed by the company and in the company to control and follow up the economic and non financial data of the company.
how the companies connect with the stakeholders.
local suppliers/ employees; W/M rate, women in responsibility charges, Kind of contract, staff turnover, accident rate, social investment, negative impacts, CO2, wáter rate, waste rate, electricities, environmental issues, etc...
How the results are got and the main measures to improve.
Corruption (companies wich apply in public offers or they usually keep relation with public institutions), Reputation risk, environmental risks, HR risks,
Direct and indirect positive impacts: (positive impacts) In terms of increasing local ( local or national) value, creation of new business, employees, social investments, depend on the business, they may also add positive impact in environmental áreas.
Economic, social and environmental negative impacts: Problems with communities ( ex: bringing a significative amount of foreing people to live in the area during the construction, even worse in poor towns; it may increase temporarily the incomes in the town and it may create a bigger problem when they leave (if the development is not sustainable and there is not communication to the towns)...
An explanation may be published justifying why the information cannot be published.
1 (best option)
2 (second preferred option)
 
 
 
 
It must be a clear guideline with enough information to get useful reports.
5
There are sensitive sectors where stakeholders needs to have more detailed information in specific áreas and it is very important to be identified: you will increase the efficience of the reports.
6 (most in line)
4
5
3
2
1 (least in line)
Could be interested if other national policies are analysed to get best practices of each country/ sector
An integral manual could be great because it is on line with the differents rules as well as include all the main cocepts in a document so you may reduce your time elaborating the Report.
Consider all large companies([ID97])
Absolutely because the level of impact, risk, incomes, etc... are not the same for all the companies. A guideline should be published for each main sector/ profile of company.
Yes([ID96])
Yes([ID96])
Global Reporting Initiative. Related to social investment, we apply the methodology of LBG.
Yes([ID96])
This is a sensitive matter that must be boosted. With more clarity about diversity policy, we´ll get more efforts to be better.
 
a private individual(public-replying-as)
Laura Bello
 
 
 
 
 
 
 
 
Spain([ID48])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8
6
5
3
7
4
2
9 (most important)
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
In my opinion non-financial information should be addressed to all stakeholders, since different interested parties would be interested in different aspects related to the company´s activities. I think it would be interesting to see reports which include specific chapters addereed to specific stakeholders (each company should address its material issues regarding each specific stakeholder).
4
2
3
7 (most important)
5
6
 
 
Materiality analysis should provide a four-way view for the company: which issues are key for the company, how developed their management is, which ones are important for stakeholders and how those stakeholders value the way the company is managing those issues. That information should be most useful to adequately evaluate and report both past actions and plan future activities.
3
I tend to think more detailed information on what to report and how to report it would be more useful to both companies and users, always bearing in mind there are a lot of different reporting guidelines which can be used for this purpose. However not every company fits in a certain profile or sector and that could make more difficult their reporting process.
 
 
 
 
 
 
 
 
 
 
1 (best option)
 
 
2 (second preferred option)
 
 
In my opinion, current reporting guidelines provide enough information about KPIs. Companies should be able to decide which non financial information is relevant to their stakeholders and therefore should be included in their report.
3
I think specific sectoral issues relevance changes with time, so the guidelines should be reviewed and updated periodically to include material information.
6 (most in line)
2
1 (least in line)
3
4
5
Reporting based on past actions but a more future looking focus
There are many different frameworks and the EU guidelines should not aim to become just another one of the list. I would suggets a more forward looking approach; it is important to know what companies have done, but it is equally interesting to understand what sustainabily aims the company contemplates. Many times it feels like companies do not even know where they intend to be in the future
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
General contents regarding not financial info should not be different, but the guidelines may include indications on how to report more specific info, so companies have both a general framework to follow (as detailed as possible regarding common sustainability aspects) and a helpful guide to develop their report.
Yes([ID96])
Yes([ID96])
GRI, Global Compact, AA1000
Yes([ID96])
Any policy regarding the board should be as transparent as possible.
 
an organisation or a company(organisation-replying-as)
 
Fondazione Sodalitas
 
No(no-transparency-register)
 
Non-governmental organisation([ID11])
 
 
 
Italy([ID36])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
5([ID21])
2([ID9])
3([ID10])
4([ID20])
6([ID22])
7([ID23])
8([ID24])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
All users of information, not only those with economic interest (investors, employees, suppliers), because other entitled key stakeholders are also consumers (buying decisions), Institutions, communities (licence to operate)
6([ID36])
5([ID35])
4([ID34])
7 (most important)([ID37])
3([ID33])
2([ID32])
 
 
Responsibility for "impact on society" is the key concept in the CSR/RBC definition
4([ID54])
General principles are not sufficient, also some indications about recommended approaches an solutions are uswful for capacity buildings of those in charge with drafting Non-Financial Statements without previous experience in sustaianbility reporting.
Very important to clarify that there is only one business model for the enterprise as a whole (or an independent business unit) -based on focus/commitments like shared value, sustainable products, core competences, open innovation,...- while there are several specific Policies addressing environmental, socilaand employees, human rights.... matters
Policy statements should be approved at the most senior level of the enterprise and communicated internally and esternally, setting out its responsibilities, commitments and expectations concerning the matters addressed
Risk-based process with the purpose to identify, prevent, manage, mitigate and account for how the enterprise addresses the negative impacts directly linked to its operations, products or services, or indirectly through its supply chain.
Transactions with customers and suppliers, with special attention for the Supply Chain perspective
Metrics for measuring and planning non-financial performance
Encompasses both short-term output of policy inputs and longer term impacts
Potential adverse impacts identified (through appropriate due diligence/materiality assessment) for saliency and likeliness of occurrence,
Conseuences, outpots caused by activities
Negative impacts generated, affecting the environment, employees, communities....
Disclosure of negotiations, or other confidential information, which might prejudice the competitive position of the enterprise
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
"One size fits all" approach cannot be applied, given the sector/size driven great diversity in issues and challengeas, and flexibility should be granted to companies in deciding about the appropriate KPIs to use, avoiding a fcomprehensive, mandatory list. However the choice of frameworks or indicators should be briefly explained (eg import for perfprmance planning...)
4([ID107])
Sectoral guidelines, beyond the one on coflict minerals, might be useful for critical/high risk/multi-layer supply chains: agricultural products, garment, costruction....
2([ID81])
5([ID84])
6 (most in line)([ID85])
4([ID83])
3([ID82])
1 (least in line)([ID80])
The list is already complete
guidelines are non replacing complementary existing frameworks
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
As future enlargement is likely, capacity building with a gradual approach is appropriate
 
 
 
No([ID97])
A policy statement on criteria for nomination and actual composition is a valuable first step
 
a private individual(public-replying-as)
Alessandra Piloni
 
 
 
 
 
 
 
 
Italy([ID36])
 
Reporting/Communication([ID4])
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
4([ID20])
6([ID22])
5([ID21])
3([ID10])
9 (most important)([ID25])
2([ID9])
7([ID23])
8([ID24])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
The non financial informations are a foundamental added value that concerns particularly the effect of the action of the businesses on collectivity, on civil society, on consumers as peolple, as citizens. Not as target of marketing or as stakeholders to whom the businesses is talking to communicate financial informations or to promote their products/services in order to sell them.
2([ID32])
4([ID34])
5([ID35])
6([ID36])
3([ID33])
1 (least important)([ID19])
 
 
I think that, as features that make a piece of information relevant for the purposes of the non-financial statement, is important most of all to understand the impacts of the company’s activity (environmental sustainability,social engagement in the collectivity,rights of workers, dialogue with consumers..) and these informations are also much important for all stakeholders of the businesses.
4([ID54])
I think It is better to put forward (obligatory) solutions in a detailed manner, including specific sectorial issues, leaving to the businesses only a little margin of freedom of voluntary integration to these information. Unfortunately, untill now,very few businesses did understand the huge added value of this kind of real engagement and of communicating it properly.
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
 
I think that first of all the Guidelines should include a comprehensive list of KPIs, general and sectoral just to help businesses to be not unclear in explaining these non financial information. Than, the GUIDELINES should highlight key principles on how to disclose relevant KPIs and complementariness with narrative and/or financial information as applicable.
5([ID108])
This, as mach as are current themes today current and important as regards CSR (palm oil free for example) have to be communicate by businesses, not hidden.
1 (least in line)([ID80])
5([ID84])
4([ID83])
6 (most in line)([ID85])
2([ID81])
3([ID82])
Starting from the know how of existing certifications (UN Global Compact,....) the guidelines should refer to them but going further, detailing more the non financial informations for each sector.
Getting inspiration from them, starting from their know how but detailing them more for each sector, in collaboration with the stakeholders and with experts of each sector. Doing that, the guidelines should be able to make an efficient synthesis of rules, to allow businesses to follow them with clarity
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
The basic guidelines should be the same for all, as a sort of list of basic priciples, but their applications should be specific and declined to the different sector, in order to render them and their application the most effective possible.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
beacuse today this point is a indicator of civilization
a private individual(public-replying-as)
Anne-Claire Blet
 
 
 
 
 
 
 
 
Switzerland([ID50])
 
Other([ID7])
Transport and logistics
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
7([ID23])
5([ID21])
4([ID20])
2([ID9])
8([ID24])
3([ID10])
6([ID22])
9 (most important)([ID25])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Transparency in disclosure will push companies towards more environmentally and socially-friendly behaviours and development strategies ONLY IF each and every actor concerned by these strategies can access information and hold companies accountable.
4([ID34])
6([ID36])
5([ID35])
3([ID33])
2([ID32])
7 (most important)([ID37])
 
 
v v
5([ID55])
Detailed guidelines will ease everyone's understanding of the non-financial information disclosed and will enable comparisons among companies (which will guarantee improvements towards more environmentally and socially friendly strategies as competition will integrate non-financial statements).
 
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
 
If the idea is only to define principles, then just provide companies with an hyperlink to GRI, OECD or UN Global Compact. The EU can do better, and should by providing detailed and comprehensive KPIs.
4([ID107])
v v
6 (most in line)([ID85])
5([ID84])
4([ID83])
3([ID82])
2([ID81])
1 (least in line)([ID80])
No other approach but guidelines including detailed and exhaustive solutions
The EU guidelines should become a reference. Nothing else, nothing less.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
v
No([ID97])
 
 
Yes([ID96])
Transparency will lead to better diversity!
 
a private individual(public-replying-as)
Roberto Raccanelli
 
 
 
 
 
 
 
 
Italy([ID36])
 
Accounting([ID4])
Auditing([ID6])
Reporting/Communication([ID4])
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
3([ID10])
7([ID23])
1 (least important)([ID8])
4([ID20])
5([ID21])
6([ID22])
8([ID24])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Non-financial statements should speak to all relevant stakeholders
2([ID32])
3([ID33])
7 (most important)([ID37])
6([ID36])
4([ID34])
5([ID35])
 
 
Relevance for stakeholders is the main matrix dimension for materiality.
5([ID55])
Guidelines can give a stable framework to Companies.
Brief and short explanation
Brief and short explanation
Brief and short explanation
Brief and short explanation
Detailed explanation, including a detailed description of formulas, definitions, field of application etc.
Brief and short explanation
Brief and short explanation
Detailed explanation, including a detailed description of field of application
Brief and short explanation
Detailed explanation, including a detailed description of how to omit and when it is permitted
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
 
The Guidelines should give a detailed explanation regarding KPI disclosure in order to avoid misunderstanding, voluntary omissions etc.
5([ID108])
This is a key issue for sustainability
6 (most in line)([ID85])
2([ID81])
3([ID82])
4([ID83])
5([ID84])
1 (least in line)([ID80])
GRI
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
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
No difference
No([ID97])
 
 
Yes([ID96])
This is a key issue for sustainability
 
an organisation or a company(organisation-replying-as)
 
ALRO Slatina
 
No(no-transparency-register)
 
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Romania([ID45])
 
Other([ID7])
Industry - Metals
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
6([ID22])
7([ID23])
3([ID10])
9 (most important)([ID25])
8([ID24])
4([ID20])
5([ID21])
2([ID9])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
The non financial statement should be primarily addressed to all the interested stakeholders of the entity, including investors, suppliers, clients, local community, government and employees.
2([ID32])
4([ID34])
7 (most important)([ID37])
6([ID36])
5([ID35])
3([ID33])
 
 
All the above features are desirable to have by the non financial statements. The piece of non-financial information should be relevant to those that are most interested by it: investors, suppliers, customers, government, employees. Each of these stakeholders will be interested by various aspects. In our opinion, the impact of the entity's activity on environment and society are very important.
3([ID50])
The inclusion of the non financial information is mandatory. If they are extremely detailed, then this will become like a box-ticking exercise. However, we consider that a certain degree of detailed guidance would be welcome, as it would provide examples to the companies/organisations on what to include, and what is expected of them.
The guidelines should indicate to the organisations/companies what is expected of them in terms of business model. It would be good for the guidelines to explain what it is meant by the legislator by "business model", and in what detail the companies must describe it.
The guidelines could define what kind kind of policies the companies have to disclose. The GDL could also provide suitable examples for various types of policies.
This requirement may be a little unclear for some entities. Particularly here the guidelines should make clear what is that the companies must mention. We think it would also be good for the guidelines to give some examples, and also to explaining why mentioning due diligence processes is important and how it serves the stakeholders.
Provide examples of suitable business relationships and also define what it is meant by business relationships. Probably, only relationships that are significant enough (over a certain threshold) should be included.
Explain to the entities what kind of KPIs they should include, and what these should measure.
Here I believe that the guidelines should make clear to the entities/companies what is expected of them, what kind of outcomes are required and what types of policies. Also, possibly define some time-frame for the policies to be considered (say, for instance, in the last 5 or 7 years).
Give an explanation of what is required from the companies, what are the most important types of risks that should be mentioned, and what explanations or level of details should be given related to the risks.
Again, here, the guidelines should mention what types of activities the directive refers to, and what kinds of impacts should be mentioned. Also, we believe it would be good to mention some time-frame for the impacts or activities (say, the last 5 years).
Same as before. In our opinion, this point can be confused with the previous one, so the guidelines should be clear about what is required, and, possibly, why it is important and why it should be included in the administrators' report. Actually, for every piece of information (risks, policies, due diligence), you might want to explain why it is important and why it should be included.
Here, again, explain what it is meant by this and what and when the companies should mention. Explain what is meant by exceptional cases and also by prejudicial. Maybe give also some examples.
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
 
There is a balance between the guidelines being too general and them being to specific. In our opinion, if they are too general their utility will be limited. They should both offer general principles, and also give examples of several KPIs, so that companies/organisations could understand what is required from them and have some appropriate KPIs available to use.
3([ID106])
We believe the guidelines should include guidance. Or, maybe better still, create a separate document for sectorial guidance. This can prevent the guidelines from becoming too large. They should not become too large.
5([ID84])
6 (most in line)([ID85])
3([ID82])
2([ID81])
4([ID83])
1 (least in line)([ID80])
The guidelines should be complementary to other frameworks.
Indeed, there are many frameworks. We believe the GUIDELINES should not become too prescriptive, they should remain guidelines. They may utilise examples from other frameworks. We believe that the use of terminology from other frameworks should not be forbidden or discouraged. All the frameworks are recognised and available to use. The Guidelines may work together with the other frameworks.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
There should be only one version of the guidelines, available to all targeted companies. We think that the authors of the guidelines should keep the guidelines aimed at its targeted audience, that is the organisations under the scope of the DIRECTIVE.
Yes([ID96])
Yes([ID96])
CNVM Romania (Comisia Nationala a Valorilor Mobiliare) - ASF
Yes([ID96])
Yes, in order to encourage board diversity with the companies.
 
an organisation or a company(organisation-replying-as)
 
Croatian Business Council for Sustainable Development
 
No(no-transparency-register)
 
Industry association([ID9])
 
 
 
Croatia([ID24])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
5([ID21])
6([ID22])
1 (least important)([ID8])
8([ID24])
4([ID20])
7([ID23])
2([ID9])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
NF repots should serve as a tool to stakeholders engagement to help companies develop and execute their CSR programs and create them according to the interest and expectations of their specific stakeholders. NF reports should serve as a tool for companies to contribute to sustainable development.
1 (least important)([ID19])
2([ID32])
6([ID36])
7 (most important)([ID37])
3([ID33])
4([ID34])
 
 
The purpose of the NF reporting is to provide an insite on how company impacts environment and society and to answer how it managess specific topics of interest to its stakeholders. The report should be relevant to investors and other shareholders but only to uderstand how company manages its non-financial risks also important for the sucess of the company
3([ID50])
The guidelines should provide framework and minimal KPI that need to be considered but have to leave to the company to frame the detailed agenda of the report depending on its specific impacts and materiality of certain issues.
It is important to see how company is being managed and how it manages its non-finacial impacts. The accent of the information should be on the role of the managers in non-financial matters, process of decission making considering non-financial risks and responsibility of managers to manage non-financial risks
Report should show that policies include non-financial indicators.
Should show that it includes non-financial risks and impacts
Should show responsibility of company in relationships with shareholders, competitors, customers, suppliers and other stakeholders in the market
There should be sufficient number of KPI that show impact of the company to environment as well as to show labour rights, investments in labour and community...
 
It sould clearly state what non-financial risks are most important and how company manages these risks.
Information needs to be relevant to show material impact of the specific acitivites executed in order to manage non-financial risks.
 
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
 
My experiance shows that if KPIs are not clear, companes tend to bend the rules in reporting relevant issues
5([ID108])
Same as above
1 (least in line)([ID80])
6 (most in line)([ID85])
5([ID84])
2([ID81])
3([ID82])
4([ID83])
To make general framework and guide towards using G4 gudelines
Gudielines should give general framework and guide companies towards using G4 guidelines
Consider all companies([ID98])
The guidelines should be broader to be user-friendly towards all companies that wish to report regardless of the size.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
I believe that the companies should be encourage to reconsider their policies on criteria for board members.
 
an organisation or a company(organisation-replying-as)
 
Ramboll Environ
 
No(no-transparency-register)
 
Consultancy, law firm([ID7])
 
 
 
United Kingdom([ID52])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
8([ID24])
6([ID22])
3([ID10])
2([ID9])
5([ID21])
4([ID20])
7([ID23])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Increasingly, all societal stakeholders have an interest and a right to know of the present and future impacts of a company's activities in the sustainability context. Reference to this information in the public domain will be an important communication channel for all with a vested interest, and for those less directly impacted but that may need to view disclosure.
2([ID32])
6([ID36])
3([ID33])
7 (most important)([ID37])
5([ID35])
4([ID34])
 
 
A first tier of decision making will be based on the existing, potential and perceived impacts of activity. This provides the context required to form a understanding of how a company has positioned itself (commitment and strategy) and responds to such risks/challenges, leading to decision making, internally and external, on the basis of how effectively the company is managing the risk(s).
2([ID49])
Level of reporting detail should be conveyed in principles and criteria guidance that will enable a company to present its information in an understandable, reliable and meaningful manner. There is a need for prescriptive guidance and company's must use initiative and endeavour to bring this into the reporting, including with the use of existing sector guidelines and reporting frameworks.
It will be important for a company to bring 'sustainability context' to the reader, whether as a section in the ARA or a stand alone non-financial impacts account. This is necessary for the user to develop the relevant link between present and future impacts/risks and to form opinion over the adequacy of a company's response to these (through its reporting on policy, position and performance).
Policies convey the level of commitment around a company's principal risk areas. Guidelines should show companies how to connect the reader to the commitment and therefore how and the extent to which the policy is implemented, embedded and monitored. The guidance could also give steer on review and revision of policies to meet changes in an evolving risk arena.
Building on 'Policies' above, guidance can include how companies should describe the governance structure emplaced to make decisions on risks posed due to business activities, services and products; and the structure emplaced that identifies and manages those risks (and opportunities) on a on going basis.
Business relationship types can be usefully set out in the guidance to reduce uncertainty/ambiguity over what a reporting company is and is not to include (JVs, subsidiaries, suppliers etc). This should elaborate on the degree of responsibility, control and extent of influence the reporting company has over such relationships, to provide direction on what impacts/risks to be captured in reporting.
Obvious guidance on developing meaningful and measurable indicators should be a requisite. Reference can generally be made to the Global Reporting Initiative G3.1/G4 that provide ready made and comparable KPIs for company reporting, but there should be emphasis on ensuring that KPIs are relevant to the risk, impact, issue, opportunity and that they reflect achievement against realistic targets.
Companies should be guided on how to report that impacts/risks have informed policy making (see above also) and that processes and measures for managing and reducing impacts/risks, and for improving performance align with policy. This needs to include information on internal assurance and review approach that ensures the policy remains for for purpose, tying in with b. and c. above.
Principal risks reporting should be on the basis of the wider risk landscape, for example setting out a matrix and providing a description on how they are identified, considered and prioritised. A company needs guidance on what to include/exclude from its non-financial account and therefore it must be clear to the reader what underlying process achieves this - see c. above also.
Ideally this will relate to the extent of what (potential) impact and upon which stakeholder, achievable with an inclusive and complete reporting process, which company's should achieve over time. As a minimum impacts should link to the impacted stakeholder or media (eg environment), providing descriptive content on the nature of the impact, its cause and effect.
As for h. above the company needs to convey the extent of the impact and, for adverse impacts, stakeholders and media affected, the nature of the impact and it's (root) cause. It should elaborate on the medium to longer term as well as immediate effects of the impact as well as timescale scenarios for remediation and corrective/preventive action, where appropriate.
The guidance must emphasise that omissions are to be justified, and that the justification needs to provide the report user with sufficient explanation, including context and a balanced rationale. Commitment to include wherever possible issues/impacts omitted in current reporting should be encouraged in the guidance.
1 (best option)([ID68])
2 (second preferred option)([ID69])
 
 
 
 
Obvious guidance on developing meaningful and measurable indicators should be a requisite. Reference can generally be made to the Global Reporting Initiative G3.1/G4 that provide ready made and comparable KPIs for company reporting, but there should be emphasis on ensuring that KPIs are relevant to the risk, impact, issue, opportunity, and that they reflect achievement against realistic targets.
2([ID105])
In the interests of innovation, information quality and derivation of appropriate performance measures and indicators, the guidance should allow companies sufficient autonomy and flexibility on deciding what risks and impacts to include in reporting. It should also provide direction on where to gain knowledge on process, supplemented with sectoral guidance - a reference list would be useful.
2([ID81])
6 (most in line)([ID85])
5([ID84])
4([ID83])
3([ID82])
1 (least in line)([ID80])
see 5e, 6.1, 7.1 above.
Alignment with other international and EU reporting frameworks will be necessary and the guidance should encourage companies to use these wider existing reporting platforms as a basis for this reporting also. Where national reporting frameworks/guidance are being followed then how a company addresses items a-j of Q5 should be revisited to ensure context and coverage.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
Non-financial report guidance exists in the public domain, at international and country level (see 8.1). To open the guidance up to all reporting organisations may dilute the effectiveness and uptake of this guidance. As EU legislation pushes out to capture other entities, the guidance should keep pace also, using such intervals as opportunity for revision. Prioritise responsible investment cos.
Yes([ID96])
Yes([ID96])
UNGC Danish Financial Statement Act (matters on CR and gender composition of management)
Yes([ID96])
Clarity in the guidance on the context of a diversified board will be necessary. This could allude to the EU's proposed threshold of 40% of the under-represented sex in NEB positions in listed companies by 2020 but should also leave interpretation open (for eg UK's position merit, against objective criteria and with due regard for the benefits of diversity).
 
a private individual(public-replying-as)
Aleksandra Stanek-Kowalczyk
 
 
 
 
 
 
 
 
Poland([ID43])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
6([ID22])
4([ID20])
2([ID9])
3([ID10])
8([ID24])
5([ID21])
7([ID23])
 
 
The investment community in a broad sense([ID17])
 
the main reader should be investment community while report should show how company builds the value, what are the social and environmental risks etc. However, every company preparing report can and should define its key stakeholders group (but not too many) that would be the readers of the report and make sure they find valuable data for them.
3([ID33])
4([ID34])
2([ID32])
6([ID36])
7 (most important)([ID37])
5([ID35])
 
 
the reader of the report should be able to undestand (based on the data disclosed) how is company performing, what are its strenghts and weaknesses in terms of non-financial aspects, what are the risks and chances and how company is managing the non-financial issues.
5([ID55])
too general guidelines will not be useful for the companies that never reported before, while they may not understand them properly, these will also give companies the space to omit the concrete indicators and data that may be material, but not most convienient for the companies.
It could bse on the example of the IIRC approach, however with clear definitions and examples what can be an input or output.
that is quite well undestood for companies - just the definition of the plicy + information what policy should consist of
best - detailed information on what actions in such due dilligence process should be taken
definition + examples
definition + examples - best - for various aspects/ topics + information what IS NOT a KPI (.e.g. a statement tht does not allow to see the performance/ results)
 
how to define them + definition + examples (of risks itself and how these should be described)
definition of the impact + examples + brief explanation where is he difference between outcome and impact
as above
reasons why information can be ommited + examples (on such information and way it is described)
 
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
guidelines should provide the list of selected/ proposed KPIs + give the hints for the companies how to define others that are material
as above
5([ID108])
Guidelines should include guidance on specific sectoral issues - however with remark that it is not the full list/ it is a guideline/ proposal and the company should always make sure that defined all material issues by itself.
3([ID82])
4([ID83])
6 (most in line)([ID85])
2([ID81])
5([ID84])
1 (least in line)([ID80])
guidelines should show the reader how by addressing certain issues he/she can fulfill the requiremens also of other frameworks
as above
Consider all large companies([ID97])
no. the companies that that are not included in the scope of directive should also prepare/ be ready to disclose non-financial data based on the best developed practices.
Yes([ID96])
Yes([ID96])
GRI
No([ID97])
the information in directive is quite clear.
 
a private individual(public-replying-as)
Agathe Bauer
 
 
 
 
 
 
 
 
Austria([ID21])
 
Accounting([ID4])
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
4([ID20])
5([ID21])
9 (most important)([ID25])
7([ID23])
2([ID9])
3([ID10])
6([ID22])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
The non-financial statement gives all kinds of users the opportunity to have access to e.g. diversity and social topics. The broad public might also be interested in these topics (to watch over the companies), even though the shareholders will have the most interest in this information.
2([ID32])
4([ID34])
3([ID33])
6([ID36])
5([ID35])
7 (most important)([ID37])
 
 
The management of non-financial risks is an important part of business success nowadays. Missmanagement might lead to huge losses for the company and its investors.
4([ID54])
More detailed information would help the companies in creating reports - examples and sectoral topics might be useful. However it shouldn't be too detailed to ensure a bit of freedom.
Give the companies the freedom to answer
 
According to Ruggie's Protect, Respect, Remedy
As many relationships as possible but only when the option to influence the partners exists.
 
 
Like in the text of 2014/95/EU
 
 
 
 
1 (best option)([ID68])
2 (second preferred option)([ID69])
 
 
 
A connection to other frameworks would be useful to not just provide another framework but to connect the Frameworks and the guidelines.
5([ID108])
Both are very important issues - their management should be a main point of the guidelines in my opinion.
1 (least in line)([ID80])
4([ID83])
6 (most in line)([ID85])
5([ID84])
3([ID82])
2([ID81])
Anything else than creating a framework is useful
Links to existing frameworks are very important to avoid more complexity regarding the frameworks. Links and comparisions of the content of the frameworks are essential.
Consider all large companies([ID97])
If the scope is widened by the country - it would be useful to care also for these companies. However I think it would go too far to consider all companies now - SME's would need special facilitation.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
Diversity should be considered like a non-financial topic - to me it's part of the game.
 
an organisation or a company(organisation-replying-as)
 
Fondation Nicolas Hulot pour la Nature et l'Homme
 
No(no-transparency-register)
 
Non-governmental organisation([ID11])
 
 
 
France([ID30])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
6([ID22])
3([ID10])
5([ID21])
1 (least important)([ID8])
2([ID9])
8([ID24])
7([ID23])
9 (most important)([ID25])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Les effets sociaux, environnementaux et sociétaux des activités des entreprises et de leurs produits ou services affectent l’ensemble de leurs parties prenantes, des actionnaires aux organisations de défense de l’environnement et des droits de l’Homme, les riverains et les citoyens. Tous ont le droit de connaître les risques potentiels, les mesures prises pour anticiper et réduire ces risques.
5([ID35])
4([ID34])
2([ID32])
6([ID36])
3([ID33])
7 (most important)([ID37])
 
 
Les informations non financières sont priorioritairement importantes à la fois, pour la compréhension par les différentes parties prenantes de la façon dont les entreprises prennent en compte les impacts de leurs activités et produits, et pour le pilotage de ces risques par le management.
5([ID55])
Les principes généraux existent déjà dans les différents codes internationaux. Ils ne permettent pas toujours de définir des plans d'action opérationnels, et donc de présenter des informations concrètes sur les différentes thématiques de la responsabilité sociale, environnementale et sociétales des entreprises
La finalité de l'entreprise n'est pas uniquement financière (profit). Elle est aussi économique (durabilité des activités et des emplois), sociale (conditions de travail des salariés), environnementale (préservation des ressources naturelles et de la biodiversité, climat), et sociétale (rôle de l'entreprise dans la collectivité et le "vivre ensemble"). Il faut un équilibre entre ces missions.
Pour passer des principes à la mise en oeuvre, il faut définir des objectifs concrets, quantifiables, inscrits dans une perspective à moyen/long terme, des indicateurs de résultats, et des mesures correctrices lorsque les objectifs ne sont pas atteints aux différentes étapes de progression prévues.
Le devoir de vigilance doit être défini tout au long de la chaîne d'approvisionnement. Il ne suffit par que l'entreprise définisse des politiques, comme les critères de responsabilité à remplir par les fournisseurs et leurs différents sous-traitants, il faut également vérifier leur respect par des audits indépendants aux différents stades de la chaine de valeur.
L'entreprise doit prendre en compte les effets de ses produits par les usagers. Par exemple, les guidelines doivent préciser que l'entreprise doit informer sur la façon dont elle contribue à réduire les émissions de gaz à effet de serre par ses clients : moindre besoin en énergie pour l'usage du produit, durabilité, affichage environnemental et social, conseils aux consommateurs.
- Gouvernance : place et rôle de la responsabilité RSE au sein du board et de la direction générale - Social : emplois, sécurité, réduction des inégalités, formation - Environnement : GES (engagements européens), pollutions, préservations des ressources naturelles, biodiversité - Sociétal : devoir de vigilance, évasion fiscale, droits de l'homme
- Résultats obtenus - Mesures correctrices pour les retards par rapport aux objectifs
Présenter la liste des risques potentiels identifiés par l'entreprise, avec leur degré de probabilité et de priorité Présenter les risques et les attentes présentés des différentes parties prenantes
Présenter l'évaluation des conséquences potentielles des risques. les mesures prises pour anticiper, prévenir, réduire, éliminer et réparer les dommages causés
Expliquer dans le reporting comment l'entreprise prend en compte les attentes, les plaintes, et les propositions des différentes parties prenantes par un dialogue structuré.
Les guidelines doivent bien préciser le sens du "comply or explain", qui ne doit pas être utilisé pour éviter de répondre aux questions, mais être réservé soit aux sujets réellement non pertinents pour les activités ou produits de l'entreprise considérée, soit aux cas où l'information pourrait être préjudiciables en essayent de bien définir ces exceptions qui doivent être exceptionnelles
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
 
Le reporting extra financier doit permettre les comparaisons, à la fois pour l'entreprise qui peut se benchmarker pour progresser, et pour les parties prenantes qui doivent pouvoir identifier les meilleurs comportements. Ce qui implique des KPIs comparables. C'est le rôle des institutions d'encadrer ces KPIs
5([ID108])
Les effets des activités des entreprises et de leurs produits varient considérablement d'un secteur à à un autre. Il doit y avoir des approches spécifiques par grands métiers
6 (most in line)([ID85])
2([ID81])
3([ID82])
5([ID84])
4([ID83])
1 (least in line)([ID80])
pas d'autre approche
Les entreprises, en particulier les PME, qui représentent le plus grand nombre, se plaignent, à juste titre, de la multiplicité des règles, volontaires ou réglementaires. Les guidelines européennes, doivent permettre une synthèse et une référence commune au plus grand nombre possible d'entreprises européennes.
Consider all companies([ID98])
Les effets des activités et des produits des entreprises sur leurs parties prenantes ne se limitent pas aux entreprises ayant une taille ou un statut juridique spécifique. Toutes les entreprises, et au delà toutes les organisations, y compris les instances publiques, les collectivités territoriales, les associations et fondations, etc. sont concernées par leurs impacts sociaux et environnementaux.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
La diversité de la composition des boards est l'une des conditions de la RSE car le board doit être le premier responsable de la politique RSE et pouvoir représenter la diversité des parties prenantes. Un board composé uniquement d'actionnaires ne peut pas véritablement prendre en compte les autres partenaires de l'entreprise.
 
a public authority or an international organisation(citizen-replying-as)
 
 
Port of Rotterdam Authority
 
 
 
 
Regional or local authority([ID6])
 
The Netherlands([ID51])
 
Other([ID7])
Ports
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
5([ID21])
7([ID23])
3([ID10])
2([ID9])
6([ID22])
4([ID20])
8([ID24])
1 (least important)([ID8])
No suggestions
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Financial information is primary useful for stakeholders with an economic interest. Non financial information is useful for all kind of stakeholders with other (planet/people) interests
2([ID32])
3([ID33])
6([ID36])
7 (most important)([ID37])
4([ID34])
5([ID35])
1 (least important)([ID19])
No suggestions
Disclosing non financial information is important for transparancy about the impact of an organisation on society. Not only transparancy to stakeholders but also transparancy to the company itself because of awareness about it's own impact.
1([ID48])
It is not possible to prescribe relevant detailed solutions for all kind of organisations
General description including products & services and sources of revenues
Long and midterm term plan and objectives
General description of process
 
Description and scores of highest level KPI's (on board level)
Realised products, services and psoitive and negative effects on environment (quantitative if possible)
General description of strategic risks and measures to mitigate them
Combine this topic with topic f (outcome of policies)
Combine this topic with topic f (outcome of policies)
Explaination why information is omitted
1 (best option)([ID68])
 
 
2 (second preferred option)([ID69])
 
 
Some worldwide general KPI's are useful (for instance diversity, CO2). But some KPI's are specific for the kind of organisation and should be free to choose
1([ID104])
I believe in principal based reporting guidelines instead of rulebased reporting guidelines in worldwide/european guidelines for all kind of organisations
2([ID81])
3([ID82])
4([ID83])
5([ID84])
6 (most in line)([ID85])
1 (least in line)([ID80])
No suggestion here
It's effective and efficient to use or refer to other existing frameworks
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
No I prefer consistency in guidelines
Yes([ID96])
Yes([ID96])
Global Reporting Initiative
No([ID97])
It's clear enough now
 
an organisation or a company(organisation-replying-as)
 
Schroder Investment Management Ltd
 
Yes(yes-transparency-register)
997906814697-71
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
United Kingdom([ID52])
 
Investment management (e.g. hedge funds, private equity funds, venture capital funds, money market funds, securities)([ID6])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
2([ID9])
1 (least important)([ID8])
3([ID10])
9 (most important)([ID25])
4([ID20])
8([ID24])
6([ID22])
5([ID21])
7([ID23])
Objective and structured; information should be provided that conveys evidence of performance and goals, rather than overly relying on discussions of commitment or aspiration
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
We suggest all users of information should be the main audience. Shareholders are the ultimate owners and have information needs that are probably broad enough to satisfy other groups with more specific interests, without risking publication of information targeted at specific groups and of limited value in forming a comprehensive view.
2([ID32])
1 (least important)([ID19])
6([ID36])
5([ID35])
3([ID33])
4([ID34])
 
 
The features listed are likely to entail a significant level of overlap (for instance investors are likely to be interested in many of the same topics as management/directors and the other features listed are likely to feature in shareholders' evaluations). A shareholder focus should therefore provide the broadest, most inclusive criteria.
5([ID55])
General principles with significant flexibility for interpretation are more likely to result in vague, high level statements unsupported by evidence or detail that can provide comparison to peers.
Companies should explain the key elements of their business activities and identify those areas in which they believe they have a competitive advantage over peers that underpins the value they create or will create.
Companies should describe key corporate policies, how they are implemented and monitored and the problem or risk they are designed to address (rather than posting policies without context of their purpose).
This should include the types of issues companies consider, the approach they take (for instance use of internal methodologies or reliance on industry standard approaches), how decisions are made and the actions taken as a result of those diligence processes.
Companies should be encouraged to identify the business relationships most important to their organisation and to provide information relevant to understanding how they strategically manage those relationships.
These should be established to encompass the breadth of key issues facing companies across sectors, as well as issues specific to each sector. They should leverage existing frameworks as far as possible to avoid redundancy.
Having identified policies and their purpose (see comment on b. above) companies should identify measures that reflect the risk they were designed to address and report its performance in those areas.
The company should identify the key risks it believes it faces, its mechanisms for monitoring those risks and the strategies it has developed to mitigate their impact.
A company should identify the major positive and negative impacts of its activities on other stakeholders and explain how each relates to its own financial performance.
A company should identify the adverse impacts it faces or has faced and explain its approach to managing them and their impacts and performance in doing so.
A company should clearly identify information that has been omitted, explain why and describe its performance in non-compromising terms.
1 (best option)([ID68])
2 (second preferred option)([ID69])
 
 
 
 
The guidelines should push for consistent, transparent and objective replies but should also leverage the expertise & experience embedded in existing frameworks, thereby also reducing the burden on companies that already publish non-financial information.
4([ID107])
Key issues can vary significantly across industries and this should be reflected in disclosures, although a core group of topics will be universally relevant and important.
1 (least in line)([ID80])
2([ID81])
6 (most in line)([ID85])
3([ID82])
5([ID84])
4([ID83])
-
Existing initiatives have evolved from the understanding and experience of organisations using them, which should be leveraged as fully as possible, rather than adding to the burden to create new measures
Consider all companies([ID98])
Differences will occur more along industry (or to a lesser extent geographic) lines than size lines and those that are relevant to companies targeted in the Directive should be relevant to most of their smaller peers.
 
 
 
Yes([ID96])
Board diversity is a demonstrably important element of their capacity to fully discharge oversight responsibilities and more information on diversity across different dimensions and policies to ensure and enhance diversity are therefore important risk elements.
 
an organisation or a company(organisation-replying-as)
 
AMF Fonder AB
 
No(no-transparency-register)
 
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Sweden([ID49])
 
Investment management (e.g. hedge funds, private equity funds, venture capital funds, money market funds, securities)([ID6])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
7([ID23])
6([ID22])
2([ID9])
3([ID10])
4([ID20])
5([ID21])
8([ID24])
1 (least important)([ID8])
We have no example.
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
All users, because ESG issues matter to everyone.
7 (most important)([ID37])
6([ID36])
2([ID32])
3([ID33])
4([ID34])
5([ID35])
1 (least important)([ID19])
We don´t know.
It´s very crucial that the management have focused on ESG due to the fact that in the long run we believe that a good ESG work will have positive impact on the companies performance.
3([ID50])
It should be very complicated for the companies if the solutions are too detailed. It needs to be a framework.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer to have more specific guidelines for comparison reasons.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We prefer a brief description in the guidelines. It should be defined by the company itself.
We would prefer detailed regulations and definitions of exceptional cases in the guidelines.
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
The challenges differ between sectors and companies.
4([ID107])
It´s necessary to regulate to move towards to a more sustainable world.
2([ID81])
4([ID83])
6 (most in line)([ID85])
3([ID82])
5([ID84])
1 (least in line)([ID80])
We don´t know.
The guidelines should have a holistic view and not be in direct conflict with other frameworks.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
The overall principles should be the same for all.
Yes([ID96])
Yes([ID96])
UN PRI
Don’t know / no opinion / not relevant([ID98])
We don´t have any opinion.
 
an organisation or a company(organisation-replying-as)
 
Greengage Environmental
 
No(no-transparency-register)
 
Consultancy, law firm([ID7])
 
 
 
United Kingdom([ID52])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
5([ID21])
7([ID23])
4([ID20])
6([ID22])
3([ID10])
2([ID9])
8([ID24])
 
 
The investment community in a broad sense([ID17])
 
The investment community will take an increased interest in such information over time, in order to better inform investment decisions. This will include existing share holders as well as prospective new share holders.
3([ID33])
7 (most important)([ID37])
4([ID34])
6([ID36])
2([ID32])
5([ID35])
 
 
All of the features will dictate whether information is relevant and will ultimately feed in to help shareholders or investors decision making. For example knowing the impacts and how these are managed are all relevant for the investors.
4([ID54])
When reviewing other non binding disclosures of information the great variety in detail and coverage can make fair comparisons difficult to do. This could be the situation here as well. The guidelines need to be flexible enough to account for different organisation types, but prescriptive enough to mean responses are relatively uniform.
This needs to set out the type of organisation, key aspects of the structure, services / products, governance, and how this relates to the key environmental, social, human rights and anti-bribery impacts of the business.
Clear reference of relevant policies, drawing out the key components and how they address the aspects of the statement. Links to full documents should be supplied where possible. Also highlight any areas where relevant policies do not exist and the plans to address this.
How the issues are identified, understood and mitigated against. Set out key responsibilities, any legal or voluntary mechanisms in place.
 
Identify how KPIs are chosen, how they are set, for how long and how often information is gathered against each KPI and current performance.
Discuss the effectiveness of policies, highlight how policies have impacted a positive change against the above KPIs.
Using the 4 key topic areas, highlight the material risks the business poses to the environment, social, human rights, bribery etc. Describe the activities undertaken, how risks occur and the severity of the risks. Describe the risk management process in place - link to policies and KPIs.
See above.
Identify what adverse impacts are and how these are managed. Changes in adverse impacts over time should be captured.
 
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
Due to the wide range of sectors it would be unrealistic to expect a prescriptive list of KPIs. Guidance should help companies understand materiality and help them to determine their own relevant KPIs through principles or signposts to examples.
2([ID105])
Significant guidance on sectoral issues already exists and should not be duplicated through the guidelines. Instead, any relevant references or sources of information should be signposted towards.
1 (least in line)([ID80])
6 (most in line)([ID85])
4([ID83])
3([ID82])
5([ID84])
2([ID81])
N/A
As above - other frameworks should be well referenced and pointed towards in the guidellines but not re-written or repeated. It will be useful to know if disclosure through other mechanisms negates the need to disclose certain information in the statement.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
The guidelines should be applicable to all companies, allowing an understanding of the process for a fair and complete disclosure to be formed. Targeted companies will know their business best and can follow a framework for ensuring their statement is as relevant as possible.
No([ID97])
 
 
Yes([ID96])
Minimum expected disclosure on diversity should be stipulated.
 
a private individual(public-replying-as)
Chris Barnard
 
 
 
 
 
 
 
 
Germany([ID31])
 
Insurance([ID9])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
3([ID10])
9 (most important)([ID25])
2([ID9])
6([ID22])
5([ID21])
8([ID24])
4([ID20])
7([ID23])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Non-financial information is of interest to q wider audience including the owners e.g. shareholders, customers, employees, government and NGOs.
2([ID32])
3([ID33])
7 (most important)([ID37])
6([ID36])
4([ID34])
5([ID35])
 
 
Clearly, is the information relevant to stakeholders?
2([ID49])
I prefer a principles-based approach with substance over form, especially given that this is a developing area for reporting and steering.
 
 
 
 
 
 
 
 
 
 
1 (best option)([ID68])
 
 
2 (second preferred option)([ID69])
 
 
Again, I prefer a principles-based approach here.
3([ID106])
Some topics deserve a more delineated approach e.g. conflict minerals.
2([ID81])
6 (most in line)([ID85])
5([ID84])
4([ID83])
3([ID82])
1 (least in line)([ID80])
As above.
Lever off existing frameworks where appropriate. This is efficient and builds on available expertise and experience.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
I prefer a principles-based approach, but accept special cases.
Don’t know / no opinion / not relevant([ID98])
 
 
Don’t know / no opinion / not relevant([ID98])
N/a
 
an organisation or a company(organisation-replying-as)
 
Crowe Horwath International
 
No(no-transparency-register)
 
Other([ID14])
International Network of Audit & Advisory Firms
 
 
Other country([ID53])
Global
Accounting([ID4])
Auditing([ID6])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
4([ID20])
2([ID9])
3([ID10])
1 (least important)([ID8])
5([ID21])
8([ID24])
6([ID22])
7([ID23])
Forward Looking
The investment community in a broad sense([ID17])
 
The non-financial information shall be expressed in language that is understandable to the investment community. The NFI has to be useful in helping investors make long term strategic financial decisions. To be successful, the disclosures need the support of the investment community and financial regulators.
2([ID32])
7 (most important)([ID37])
3([ID33])
5([ID35])
4([ID34])
6([ID36])
 
 
A non-financial statement is relevant when it provides answers to the economic, environmental, and societal agenda of the company's stakeholders, and particularly its investors. By clearly explaining the actual and future impacts of the organisation, all stakeholders but particularly investors will be able to take better long-term decisions. The statement has to focus on how risks are managed.
2([ID49])
A guideline approach enables companies to be flexible and innovative in preparing their statement. This will be more useful for stakeholders taking a prescriptive approach. Guidelines can accommodate the wide range of business sizes and industries that exist in the EU. A flexible approach accommodates different business strategies and risk profiles.
A schematic, visual representation of the business model, that clearly identifies inputs and outputs and outcomes of the company. The ‘capitals model’ suggested by the Integrated Reporting Framework is a proper model to present the business model description in a concise manner.
Policies: the companies should be allowed to provide links to their corporate websites. Policies to disclose should include, as minimum Governance, risk and compliance Environmental management People management Product responsibility Performance management Adoption of the precautionary principle Diversity and inclusion policies,
As some due diligence requirements apply in Directives under discussion and under national frameworks, the guidelines should limit the guidance to regulatory compliance with the applicable legislation.
There should be comment about relationships with "related parties" (as defined by IAS24). Disclosures shall include the contributions to political parties and other pressure groups, as well as monetary or in-kind contributions to lobbying organisations and think tanks. Coherence with money laundry regulations is critical, as well with the OECD guidelines for multinational enterprises.
There are a number of initiatives covering the measurement of non-financial performance. The guidelines could suggest the use of certain accepted measurement frameworks to avoid confusion. Initiatives like IRIS could be good source for harmonisation of KPIs in use in the financial industry related to sustainability and corporate NFI
Performance measurement against published targets is amount. Many non-financial reports fall short relying only on descriptions of the past performance, sometimes not fully disclosing targets and performance against previous targets.
There should be disclosure of the principal risks, and details of how the risks are being managed and addressed. The disclosure should be high level but sufficient to inform readers about the process to identify and manage risk.
Impact analysis could be expensive for some companies. However, guidance on impact analysis models could help businesses to understand a practice that is not common in mid-sized firms and would be useful for strategic, long-term planning.
See h above.
The omission of information has to be in very exceptional circumstances only. "Exceptional" and "seriously prejudicial" has to be careful presented to keep such omissions to an absolute minimum.
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
The guidelines can suggest the use of certain of the accepted frameworks for NFI performance measurement to avoid confusion. Initiatives like IRIS could be a good source for harmonisation of KPIs in use in the financial industry related to sustainability and corporate NFI. Existing EU rules should be observed, such as the use of best available technologies for environmental measurements.
5([ID108])
The guidelines should be consistent with developments of the SASB (Sustainability Accounting Standards Board), to ensure that location is not favouring companies regarding nonfinancial requirements. We encourage responsible supply chain compliance and reporting, as well as global harmonisation of standards on areas such as conflict mineral reporting.
2([ID81])
6 (most in line)([ID85])
4([ID83])
5([ID84])
3([ID82])
1 (least in line)([ID80])
NA
Guidelines should not be prescriptive as it would generate unnecessary administrative costs for those companies issuing non-financial reports already. A detailed/prescriptive norm would produce a situation of checkboxing where firms could not be entirely reflective of the contents expressed in their statements. Reputable frameworks such as Integrated Reporting should be promoted and used.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
Guidelines should be the same as it would ensure a consistent standard for all the companies. Successful guidelines and norms are prepared to apply to different types and sizes of organisations. (say, ISO9001, GRI.G4)
Yes([ID96])
Yes([ID96])
Article 40 of the 2006 Audit Directive.
Yes([ID96])
Diversity shall be promoted to ensure that board positions are covered by the most competent people for the position. There should not be quotas on board constituency, as without policies to ensure equality, quotas could be regarded as ineffective measures. The guidelines should promote best practices and the encouragement and development of the best talent.
 
an organisation or a company(organisation-replying-as)
 
HAWE Hydraulik SE
 
No(no-transparency-register)
 
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Germany([ID31])
 
Other([ID7])
Hydraulics
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
9 (most important)([ID25])
6([ID22])
5([ID21])
3([ID10])
2([ID9])
7([ID23])
4([ID20])
 
 
The shareholders([ID16])
 
-
5([ID35])
4([ID34])
3([ID33])
2([ID32])
7 (most important)([ID37])
6([ID36])
 
 
-
4([ID54])
comparability
 
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
-
1([ID104])
-
2([ID81])
5([ID84])
6 (most in line)([ID85])
3([ID82])
4([ID83])
1 (least in line)([ID80])
-
-
Consider all companies([ID98])
differentiated among industrial sectors
No([ID97])
 
 
Yes([ID96])
board composition and expertise
 
an organisation or a company(organisation-replying-as)
 
Pension Investments Research Consultants Ltd.
 
No(no-transparency-register)
 
Other([ID14])
Proxy Advisor
 
 
United Kingdom([ID52])
 
Other([ID7])
Corporate governance proxy advisor
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
1 (least important)([ID8])
2([ID9])
3([ID10])
7([ID23])
4([ID20])
6([ID22])
5([ID21])
 
 
The investment community in a broad sense([ID17])
 
Recent studies show that, while the level of shareholder activism has been steady across recent years, other investors have increasingly comprised ESG factors into their decisions. Non-financial statement should therefore provide the investing community with a common ground to understand the non-financial position of a company and encourage cooperation within the investment community.
2([ID32])
7 (most important)([ID37])
4([ID34])
6([ID36])
3([ID33])
5([ID35])
 
 
We believe that the purpose of the non-financial statement should be forward-looking, as the impact from non-financial activities may occur in the medium or long term. Relevant information with this respect should enable the investment community to identify future trends and possibly anticipate positive impact on their development at corporations.
5([ID55])
Guidelines should be detailed, otherwise they would be hardly applicable and may leave so much room for discretion to be useless. However, they should not include sector issues at this stage. There are already a number of voluntary sector initiatives, including on reporting, and another set of non-binding guidelines may end up confusing instead of consolidating reporting in this field.
The guidelines should be comprehensive across sectors and markets. All business models should be requested to report on the same core non-financial indicators at this stage.
Policies should outline the process and the expected outcome, possibly with targets.
The guidelines should allow reporting entities to report in detail the process of due diligence and its outcome, as well as continuous improvement efforts and periodical review of effectiveness.
 
The guidelines should synergize KPIs already available from other international institutions and consolidate the work of the EU so far on non-financial reporting. KPIs should be detailed and should include compulsory and optional ones.
The guidelines should require companies to choose a limited number of policies and monitor their outcomes across the years, so that continuity is shown.
Guidelines should require from entities to report on the main non-financial risks. Answers should be as detailed as possible.
 
 
 
1 (best option)([ID68])
2 (second preferred option)([ID69])
 
 
 
 
The guidelines should consolidate existing frameworks at this stage and create a common ground for reporting among companies, for which discretion should be limited to the respect of local legal disclosure requirements.
1([ID104])
The guidelines at this stage should create and understandable framework for reporting and assessing non-financial disclosure and its impact across sectors; they should not focus on sectoral aspects (on which there are already a number of initiatives, which can be synergized at a later stage).
2([ID81])
6 (most in line)([ID85])
5([ID84])
4([ID83])
1 (least in line)([ID80])
3([ID82])
The guidelines should include examples to show real-world cases, for reference.
The guidelines should consolidate knowledge on non-financial reporting so far and make it applicable across the EU. This effort may include reference to other framework, however territoriality and applicability are believed to be key for the success of the guidelines.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
EU has a variety of legal framework and the priority of the guidelines at this stage should be consolidation of non-financial reporting in EU. At this stage, it is believed reasonable to focus on the scope of the Directive as a starting point for testing the outcomes from the guidelines.
No([ID97])
 
 
Yes([ID96])
The guidelines should require from companies not only data but also disclosure on the process towards diversity, on comply or explain basis. Companies should not be left with the discretion of defining diversity and setting tailor-made targets; rather the guidelines should provide the EU framework for the EC goal of 40% diverse boards by 2020.
 
an organisation or a company(organisation-replying-as)
 
Hermes Center for Transparency and Digital Human Rights
 
No(no-transparency-register)
 
Non-governmental organisation([ID11])
 
 
 
Italy([ID36])
 
Other([ID7])
Non Profit Entity developing OpenSource Reporting/Whistleblowing Software GlobaLeaks https://globaleaks.org used in more than +20 countries/+35 organizations to report corruption, malpractices and human rights abuses
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
3([ID10])
7([ID23])
6([ID22])
2([ID9])
4([ID20])
5([ID21])
1 (least important)([ID8])
8([ID24])
9 (most important)([ID25])
Accessibility and promotion of reporting channel. A bad example is OLAF reporting platform, available in few language, unknown to most EU citizens, relatively complex, does not provide timely feedback to reporters. A good example are the regional ALAC from Transparency International Chapters, localized, well promoted, with an end-to-end feedback loop to reporters.
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Wrongdoing and "non good" situation could be reported by people that are just "concerned citizens" and does not necessarily are suppliers, customers or employee. That's the mistake done by many organization implementing compliance procedure for reporting, opening the reporting channel only in the intranet expecting to restrict it only to employee. A wider audience of reporters means better info.
7 (most important)([ID37])
6([ID36])
5([ID35])
3([ID33])
4([ID34])
2([ID32])
1 (least important)([ID19])
Organizing a reporting framework with digital means that enable information to be "actionable" correcting the problem that has been identified/reported, and tracking the actions done to fix it.
It's important that reporting is useful and actionable. Having too many reports or having unstructured information to be processed by compliance analyst, just does't make sense. Using proper digital reporting mechanism, with the goal to "increase information quality, reducing the information quantity" is a key goal to make a system effective.
5([ID55])
Most organizations do implement reporting system only because of a compliance requirement, so it's an obligation to be satisfied, nothing more. By enforcing very detailed procedure for reporting, including the structured questionnaires, maybe providing the technology to do it, the case management procedure and the KPI for procedural reporting, they will not be able to "implicitly" sabotage it.
Simple as possible, who sell what to who and why.
Principles of the policies summarized in a way that can be easily understood. Not piles of 60 pages policy documents that require a high skilled analyst working for weeks only to understand it.
Simple and cost effective.
Simple.
Specific to the business sector.
Specific to the business sector.
No more than top-10 risks.
N/A
N/A
N/A
 
 
1 (best option)([ID68])
2 (second preferred option)([ID69])
 
 
OpenData format to enable crowdsourced analysis.
5([ID108])
Establish detailed rules instead on relying on the bona fide and competences of the implementator. That's compliance, a boring stuff, nobody care and will just didn't consider it relevant, so it will implement low-budget.
5([ID84])
4([ID83])
3([ID82])
2([ID81])
6 (most in line)([ID85])
1 (least in line)([ID80])
N/A
Other guidelines are note detailed in the operational implementation of reporting channel, i expect this to be.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
No, the reporting categories, questionnaires and KPI can be the same across all companies. If a company is not dealing with environmental issue, will just have "0 reports" received on the environmental category. Let's be practical.
Don’t know / no opinion / not relevant([ID98])
 
 
Don’t know / no opinion / not relevant([ID98])
N/A
 
an organisation or a company(organisation-replying-as)
 
CYPRUS CHAMBER OF COMMERCE AND INDUSTRY
 
Yes(yes-transparency-register)
3199368915-29
Industry association([ID9])
 
 
 
Cyprus([ID25])
 
Not apppcable([ID8])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
7([ID23])
6([ID22])
8([ID24])
5([ID21])
4([ID20])
3([ID10])
2([ID9])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
SINCE THE INFORMATION INCLUDES A LARGE CSR ELEMENT THEN ALL USERS OF INFORMATION ARE RELEVANT.
2([ID32])
6([ID36])
7 (most important)([ID37])
5([ID35])
4([ID34])
3([ID33])
 
 
SAME AS ANSWER PROVIDED IN Q2.1 ABOVE.
1([ID48])
GENERAL PRINCIPLES SO THAT FLEXIBILITY IS PROVIDED.
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
FLEXIBILITY SO THAT THE REGULATORY BURDEN IS REDUCED.
1([ID104])
SAME REASONS AS THOSE STATED ABOVE. (Q6.1)
6 (most in line)([ID85])
5([ID84])
4([ID83])
3([ID82])
2([ID81])
1 (least in line)([ID80])
---------------
-------------------
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
--------------------------
No([ID97])
 
 
No([ID97])
--------------------
 
an organisation or a company(organisation-replying-as)
 
The Association of Investment Companies
 
Yes(yes-transparency-register)
83957346078-57
Trade union([ID13])
 
 
 
United Kingdom([ID52])
 
Other([ID7])
Trade body for investment companies including investment trusts, VCTs and REITs.
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
6([ID22])
4([ID20])
8([ID24])
2([ID9])
7([ID23])
5([ID21])
3([ID10])
 
 
The shareholders([ID16])
 
The aim of company is to operate the business in the long-term interests of shareholders. The annual report and accounts (ARA) provides shareholders with relevant information useful for making investment decisions and assessing director’s stewardship. The board and auditor report to the shareholders of the company. The shareholders are the main audience of the ARA and non-financial information.
2([ID32])
7 (most important)([ID37])
3([ID33])
4([ID34])
6([ID36])
5([ID35])
 
 
Materiality is essential in a principles based framework. Information is material if its omission / misrepresentation could influence decisions of shareholders. Shareholders need material, relevant information to exercise control over the company and how it is managed. Directors should consider whether information is relevant to shareholders’ voting decisions or shareholders’ investment decisions.
1([ID48])
Markets constantly change and regulation is slow to adapt. A principles based approach is durable and proportionate. It focuses on the purpose of disclosure, making it harder to distort information. Companies can decide what processes and controls they should operate, specific to their market and industry, whilst remaining responsible. This is effective and avoids a tick-box approach.
The business model should not be defined. Instead the requirement should be to describe what an entity does and how and why it does it. This will assist companies in providing only relevant and applicable information.
Policies should not be defined. Guidelines should encourage companies to disclose relevant policies, whether that be investment policies, accounting policies, human resource policies or other relevant issues. These may be given as examples of policies that companies could disclose. Companies should make a judgement and disclose only the relevant and material policies.
Due diligence process should not be defined. Companies should be allowed to implement processes that are appropriate for their individual complexity, size and circumstances. The guidelines should make reference to processes being “properly implemented” and “functioning effectively”.
Business relationships should not be defined. The guidelines should offer examples of types of business relationships which companies may wish to consider when assessing relevant, material relationships. For example, relationships with its suppliers, customers, employees and related parties.
KPI should not be defined. Guidelines should describe these per the UK FRC’s paper “Guidance on the Strategic Report” it says “Non-financial KPIs can be indicators of future financial prospects and progress in managing risks and opportunities. They may include, for example, measures related to product quality…”. The number of items disclosed should generally be relatively small.
This should not be defined. Guidelines should encourage companies to provide investors with a brief explanation of the results of implementing the policies as required. Guidelines should include examples to show how this may be achieved. For example a company that is a major user of energy may have a policy to reduce its energy consumption it may quantify the reduction it has achieved in the year.
This should not be defined. Guidelines should refer to the UK FRC’s paper “Guidance on the Strategic Report”. This says “Principal risks should be disclosed and described irrespective of how they are classified or whether they result from strategic decisions, operations, organisation or behaviour, or from external factors over which the board may have little control”.
The term “impact of the activity” should not be defined. Companies should be encouraged to describe the effect or influence its activities have on the matters outlined in this article. The guidelines may include a number of examples to show how this may be achieved.
The term “impact of the activity” should not be defined. Companies should be encouraged to describe the effect or influence its activities have on the matters outlined in this article. The guidelines may include a number of examples to show how this may be achieved.
This statement should not be defined. The guidelines should make it clear that in reporting on these items, the company would not be expected to disclose information which, in its opinion, would be prejudicial to its interests.
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
Guidelines should help companies meet the regulatory requirement. Companies have a good understanding of their sector and shareholders. Providing flexibility to judge what KPIs should be included will encourage good regulatory practice. It will ensure shareholders are provided with relevant information. It will help companies comply in a proportionate way, reducing cost and compliance burdens.
1([ID104])
Guidelines should support a principles-based approach. Guidelines set out overarching regulatory principles. They provide recommendations to help companies exercise judgement and meet their regulatory objectives. Guidelines cannot cover each specific sectoral issue. This would be mechanistic and unsustainable. Guidelines should take a high-level approach that makes the purpose of the rule clear.
2([ID81])
3([ID82])
4([ID83])
5([ID84])
6 (most in line)([ID85])
1 (least in line)([ID80])
.
The Guidelines should recognise that other frameworks may be useful. They should not demand that these be considered or seek to provide an exhaustive resource. They should facilitate the provision of appropriate, proportionate and relevant non-financial information and avoid conflict with other requirements.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
The Directive requires only that the Commission prepares non-binding guidelines. It is outside of its remit to prepare guidelines companies not in scope of the Directive. If companies choose to apply these guidelines, they can at their own initiative. There should be no obligation.
Don’t know / no opinion / not relevant([ID98])
 
 
No([ID97])
Article 20.1g requires large companies to disclose diversity policies. It provides sufficient information for companies to assess which specific aspects would be most relevant for them to disclose. Companies should be encouraged to apply their judgement which will result in better, more relevant disclosures. Further detail risks this disclosure becoming a tick-box exercise.
 
a private individual(public-replying-as)
pia koch
 
 
 
 
 
 
 
 
Denmark([ID27])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
8([ID24])
7([ID23])
4([ID20])
1 (least important)([ID8])
6([ID22])
2([ID9])
5([ID21])
 
 
The investment community in a broad sense([ID17])
 
I was torn between all users of information or investment community and concluded that In todays intertwined world consumers often are identical with pension scheme holders and thereby part of the investment community in a broad sense.
2([ID32])
5([ID35])
3([ID33])
7 (most important)([ID37])
4([ID34])
6([ID36])
 
 
Most important is obviously the impact of the company´s activity on the wider community and the environment
3([ID50])
A balance of both.
essential as differentiatior
important to comply with
carefully conducted including historical and future/predicatable long term consequences of activities
should be transparent
pure quantitative KPI ´s put reporting under unneccessary pressure to be creative, integrate qualitative KPI´s as well
implementation in daily actions
to be proactivly adressed
both past and future
to be taken serious and avoided
to be handled with care or omission avoided completly
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
 
no
3([ID106])
no
6 (most in line)([ID85])
5([ID84])
3([ID82])
2([ID81])
4([ID83])
1 (least in line)([ID80])
NA
in order to simplity and make comparision possible other guidelines shoudl be made unnecessary
Consider all companies([ID98])
na
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
reflect customer and consumer base
 
an organisation or a company(organisation-replying-as)
 
Tennaxia
 
No(no-transparency-register)
 
Consultancy, law firm([ID7])
 
 
 
France([ID30])
 
Reporting/Communication([ID4])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
4([ID20])
8([ID24])
2([ID9])
5([ID21])
3([ID10])
6([ID22])
7([ID23])
1 (least important)([ID8])
Auditability - Third party - International Standards
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
I don't agree with a single choice question. A prioritization would have been more relevant. The co-financial commitments, issues and KPI's are global performance levers, in that way it mean's that any stakeholder must have the opportunity to find the good data or the good information according to need.
4([ID34])
3([ID33])
2([ID32])
6([ID36])
7 (most important)([ID37])
5([ID35])
 
 
We are talking about sustainable and competitive business. The CSR reporting is a chance to understand the global performance of a company in a sustainable way. Talking about non-financial is really not a good idea. We must talk about co-financial statement to understand that the most important issue is to create value and to share it with the shareholders and the stakeholders
3([ID50])
The guidelines as general principles with a sectoral approach as SASB is doing it in the USA to be really efficient and to avoid the approximations. In fact I think that the most important is to establish a solid base of 15 mandatory KPI's for each sector. If the companies want to add data and qualitative information to ease the understanding of their global performance, why not...
Reporting on "non-financial"information means...CSR inside. Don't tell it, prove it !
Sustainable and competitive oriented
Rigorous and auditable by a third party
Report on its "non-financial" information means to report on its stakeholders mapping and dialog with. No materiality assessment without a robust stakeholders mapping
Global performance and sector oriented : really material !
Proved by the KPI's and the comments, based on the international reporting standards
Reported with transparency
Monitored by operational indicators based on the international reporting standards
Monitored by operational indicators based on the international reporting standards
Comply or explain.
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
 
With the GRI, SASB, the SDG Compass, the Integrated Reporting and the CDP, we have a strong library which give a very robust basis
5([ID108])
Materiality is the master word. (cf. SASB approach, GRI sectoral issues)
2([ID81])
4([ID83])
6 (most in line)([ID85])
3([ID82])
5([ID84])
1 (least in line)([ID80])
Neither
Why inventing a new battery of key performance indicators and guidelines.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
A mandatory basis for the targeted companies. A free usage for the other companies, the idea is to encourage
Yes([ID96])
Yes([ID96])
Global Compact (we are 45 employees)
Yes([ID96])
Once again, according to the main international standards and with the French regulation, we have a scope of disclosure.
 
a private individual(public-replying-as)
Adrian Henriques
 
 
 
 
 
 
 
 
United Kingdom([ID52])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
2([ID9])
5([ID21])
4([ID20])
8([ID24])
1 (least important)([ID8])
3([ID10])
6([ID22])
7([ID23])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Non-financial information has a very wide applicability. To restrict it to business-relevant stakeholders would limit its potential usefulness.
6([ID36])
5([ID35])
2([ID32])
1 (least important)([ID19])
4([ID34])
3([ID33])
 
 
Non-financial materiality should be understood in terms of what is important for non-financial stakeholders as well as business stakeholders.
3([ID50])
Both are important - specific examples need to be set in a more general context that principles can provide.
The business model should be described such as to reveal how the treatment of commercial matters affects non-financial impacts as well as vice versa.
 
 
Business relationships should be explained to show that the full value chain - both supply chain and 'demand chain' is included.
 
 
 
 
 
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
 
An exhaustive list of KPIs is likely to be both contentious and to fall out of date. however allowing companies complete freedom to choose what is 'relevant' may become the disclosure of what is convenient.
3([ID106])
Both are important - specific examples need to be set in a more general context that principles can provide.
5([ID84])
4([ID83])
2([ID81])
3([ID82])
1 (least in line)([ID80])
6 (most in line)([ID85])
none
The most helpful approach would be for the Guidelines to provide a mapping to other frameworks. Using the guidelines would enable companies to know how far following a given framework would satisfy the non-finanical disclosure requirements.
Consider all companies([ID98])
All companies should be considered. The actual appropriateness and possible use of the guidelines by smaller companies should also be discussed.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
Key aspects of Board diversity include sex, age and external affiliation.
 
a public authority or an international organisation(citizen-replying-as)
 
 
Università Cattolica del Sacro Cuore Piacenza
 
 
 
 
Other public authority([ID9])
University
Italy([ID36])
 
Other([ID7])
Education
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
6([ID22])
3([ID10])
2([ID9])
5([ID21])
7([ID23])
8([ID24])
4([ID20])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
I think that social and environmental information and the willingness to be transparent about the companies non financial statement are usefull for both Stakeholders, NGO and Users with Economic interest. those information are a index of Company health.
1 (least important)([ID19])
7 (most important)([ID37])
4([ID34])
3([ID33])
5([ID35])
6([ID36])
 
 
Those statement, if well verified, can be a really good instrument, so as financial reporting, to have a informaition about the company healtness.
2([ID49])
I don't think that the indication fo solution is usefull, every company have a different situation that can be solve in a different manner. Those instrument is a transparent way to communicate company informations to the wole stakeholders and NGO. Solution must be find individually in each company.
The company business model must also identify the Social and environmetal effect of the implemented plan.
Assure the compliance of national and international policies, and comunicate the companies adhesion on volountary environmental or social policies or programs
Make a risk and opportunity analiys about the company business model and social and environmental model.
Identify burdens for national or international suppliers and distributors looking also to work condition and human right about those distributors.
Guidelines like GRI define different KPI, but theose indicators must be chosed froma set of KPI on the basis of the company characteristics
Identify different KPI and hamonize the approach in the EU
Company must define a business solution to reduce the principal risks in the following years
identify also the impact of activities in scope 3
be transparent on adverse impacts of the company activities
Only for medium and small companies
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
There are different instrument ot evaluate the CSR. The guideline must define wich KPI are the most usefull and give flexibility to the company to chiese and justfy those KPI that fit the best for those companies
4([ID107])
Sure big companies must be transparent about scope 3 and supply chain performance because part of their responsibility.
1 (least in line)([ID80])
3([ID82])
2([ID81])
5([ID84])
4([ID83])
6 (most in line)([ID85])
The guidelines must addres general priciples and identify witch other framework are compliant to those principles. Indipendent framework can in that way modify some principles and in the future arrive to uniformity.
The guidelines must addres general priciples and identify witch other framework are compliant to those principles. Indipendent framework can in that way modify some principles and in the future arrive to uniformity.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
Yes, every company have an effec and a responsibility and the guidelines should ive different KPI about the company characteristisc
No([ID97])
 
 
Don’t know / no opinion / not relevant([ID98])
i don't understand what is a board diversity
 
a public authority or an international organisation(citizen-replying-as)
 
 
Wirtschaftsprüferkammer (WPK; chamber of public accountants)
 
 
 
 
Regulatory authority, Supervisory authority or Central bank([ID8])
 
Germany([ID31])
 
Auditing([ID6])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
5([ID21])
3([ID10])
7([ID23])
8([ID24])
2([ID9])
4([ID20])
6([ID22])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Because ultimately it is not known who is interested in the non-financial statement, all interest groups should be addressed. At least all interested parties should be given the opportunity to understand these informations.
2([ID32])
3([ID33])
7 (most important)([ID37])
6([ID36])
4([ID34])
5([ID35])
 
 
First of all an information is relevant if it is in the interest of the adressees (here: stakeholders in general, see Q2). Then the company's activities (including management, development), which relate to issues that need to be addressed in the statement, must be taken into focus.
3([ID50])
Both. General principles and key ideas are necessary. Furthermore examples that go into detail would be helpful . However, not all sectoral specificities should be addressed in order not to overburden the guidelines.
No long explanations necessary; maybe including naming of the business divisions
Assistance regarding the scope of the required description is needed
Explanation of what is meant by this.
Topics that can be addressed: explanation what kind of business relationships this might be, when the disclosure is necessary, why the reference to the undertaking's operations in general are not sufficient; dealing with restrictions imposed by the contract (e.g. confidentiality agreement)
See Q 6.1
Explanation of what is meant by this.
Examples of such risks are required
 
Examples of such risks are required; concretion how far the presentation should go without straining oneself
A definition of "seriously prejudicial" is necessary; clarification whether and how this must be documented
 
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
The guidelines should present a list of possible key performance indicators without presenting them as mandatory.
1([ID104])
See Q4.1
2([ID81])
3([ID82])
6 (most in line)([ID85])
4([ID83])
5([ID84])
1 (least in line)([ID80])
No other
The guidelines should not be overburdened. Therefore it seems sufficient if the guidelines contain concrete references to other frameworks.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
Since it is likely that other companies want to publish voluntary non-financial statements or similar information it would be helpful for them to get a best practice in these guidelines.
No([ID97])
 
 
Yes([ID96])
Noting that the directive 2014/95/EU includes not only changes with respect to non-financial information, but also changes in relation to board diversity, it would be helpful also to include explanations to that issue in the guidelines.
 
a private individual(public-replying-as)
luisa Balestra
 
 
 
 
 
 
 
 
Italy([ID36])
 
Reporting/Communication([ID4])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
2([ID9])
8([ID24])
4([ID20])
7([ID23])
3([ID10])
5([ID21])
6([ID22])
 
 
The shareholders([ID16])
 
The main audience should be the stakeholders, and it may be at times the investor as well as the workers as well as the community ect.
3([ID33])
6([ID36])
7 (most important)([ID37])
5([ID35])
2([ID32])
4([ID34])
1 (least important)([ID19])
n/a
Stakeholders first in a general terms because it's all inclusive and it activates a all rounded responsibility.
No opinion([ID56])
GRI guidelines is already I well done job. No need for others
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
please consider GRI G4 guidelines
 
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
please consider GRI G4 guidelines
5([ID108])
please consider GRI G4 guidelines
1 (least in line)([ID80])
4([ID83])
3([ID82])
5([ID84])
6 (most in line)([ID85])
2([ID81])
please consider GRI G4 guidelines
please consider GRI G4 guidelines
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
please consider GRI G4 guidelines
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
please consider GRI G4 guidelines
 
an organisation or a company(organisation-replying-as)
 
GC Network Bulgaria Association
 
No(no-transparency-register)
 
Industry association([ID9])
 
 
 
Bulgaria([ID23])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
7([ID23])
8([ID24])
4([ID20])
9 (most important)([ID25])
3([ID10])
2([ID9])
6([ID22])
5([ID21])
 
 
Users of information with an economic interest, such as suppliers, customers, employees, etc.([ID18])
 
The non-financial information shall be organized and presented in such a manner that is easily understood by the non-expert readers.
3([ID33])
4([ID34])
2([ID32])
6([ID36])
7 (most important)([ID37])
5([ID35])
 
 
The non-financial information shall describe the processes of performance, position and future development. It shall be connected with the direct impact of the company while doing its everyday business. It shall contain information how its behaviour is relevant to the universal principles of ethical business such as UN Global Compact and how it contributes to the implementation of the SDGs.
1([ID48])
The principle-based approach is more relevant as there is a huge variety of performance indicators. Those shall be based on the FREE will of every company in order to ensure BETTER marketing position.
Yes.
Yes.
Yes.
Yes.
Yes.
Yes.
Yes.
Yes.
Yes, if possible to measure
Yes.
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
There are internationally recognized frameworks that already have proved their usefulness, effectiveness and good reputation. The imposition of a completely new framework would be a huge administrative and market burden with no proven positive effect.
1([ID104])
Still, there are successful existing instruments such as GRI, SASB, etc. Nevertheless, a more open approach will allow to align with more universal principles - UNGC, for example.
2([ID81])
6 (most in line)([ID85])
5([ID84])
3([ID82])
4([ID83])
1 (least in line)([ID80])
To encourage companies to continue their efforts in transparency of non-financial reporting by using the existing guidelines and frameworks.
Starting from the internationally recognized ones; then go on European level and finally give general recommendations to the national framework how to align with the mentioned above.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
We realize that sooner or later the effects of the Directive will spread out on the supply chain. This means that we have to be open to disseminate and advocate the meaning and content of the non-financial reporting.
Yes([ID96])
Don’t know / no opinion / not relevant([ID98])
 
Yes([ID96])
It covers the existing regulations.
 
an organisation or a company(organisation-replying-as)
 
ČEZ, a.s.
 
Yes(yes-transparency-register)
429600710582-32
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Czech Republic([ID26])
 
Other([ID7])
Generation, trading, and distribution of power and heat, coal mining.
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
4([ID20])
5([ID21])
9 (most important)([ID25])
6([ID22])
7([ID23])
3([ID10])
2([ID9])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Diverse audience should be considered.
2([ID32])
3([ID33])
7 (most important)([ID37])
6([ID36])
5([ID35])
4([ID34])
 
 
As selected above.
1([ID48])
The guidelines should provide for sufficient flexibility and general setting, excluding sectorial issues.
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
The flexibility is the key word here.
1([ID104])
General principles are sufficient.
2([ID81])
3([ID82])
4([ID83])
6 (most in line)([ID85])
5([ID84])
1 (least in line)([ID80])
N/A
We share an opinion that current both international and EU framework for reporting are sufficiently set up.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
No.
Yes([ID96])
Don’t know / no opinion / not relevant([ID98])
 
Don’t know / no opinion / not relevant([ID98])
No opinion.
 
an organisation or a company(organisation-replying-as)
 
Future-Fit Foundation
 
No(no-transparency-register)
 
Non-governmental organisation([ID11])
 
 
 
United Kingdom([ID52])
 
Reporting/Communication([ID4])
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
4([ID20])
5([ID21])
9 (most important)([ID25])
3([ID10])
7([ID23])
2([ID9])
6([ID22])
8([ID24])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
All stakeholders are potentially influenced by a company’s broader impact on society and the environment – employees, management, investors, consumers, communities, etc. As such, non-financial statements should be prepared with all of these stakeholders in mind – not just one sub-group – so that each can easily understand the extent to which they may be impacted by a company’s activities.
3([ID33])
4([ID34])
5([ID35])
7 (most important)([ID37])
6([ID36])
2([ID32])
 
 
Society can only make true progress towards global sustainability and achieve targets like the Sustainable Development Goals when we understand the full impact of any company on society and the environment through its activities and extended supply chain. It is imperative that non-financial information therefore creates a complete picture of a company’s impact and its actions in respect thereof.
3([ID50])
Consistency of data reporting is essential to enable comparability and tracking of company progress. The guidelines themselves should lay out general principles, but point users towards external best in class frameworks which provide detailed solutions so as to avoid companies continuing to produce arbitrary data which is of minimal value. We caution against the use of sector specific approaches.
Companies should describe how and where all non-financial impacts of their business model occur, the scale of these impacts and what they are doing to mitigate them (or explaining why they are not). This section should also highlight the opportunities that the companies are pursuing with regards to increasing the well-being / sustainability of society and/or the environment.
Companies should outline policies with regards to all non-financial issues (e.g. greenhouse gas emission reduction, ensuring employee wellbeing, equality, etc.) and, very importantly, how they are measuring the use and effectiveness of such policies. Where policies are not implemented with regards to any key issues, this should be highlighted and explained.
As above, all companies should report how they are measuring the use and effectiveness of their appropriate policies. All reported non-financial data should be verified by an independent third-party auditor, such as one of the ‘big four’ or a specialist sustainability auditing firm.
Companies should track their non-financial impact throughout their supply chains – not just their own operations – and also consider the onward impact of their products and services. Hence all appropriate business relationships should be drawn into the guidelines.
The guidelines should seek to provide the key principles for reporting of KPIs alongside narrative description and relevant financial information, but reference best in class external frameworks for detailed guidance. Such frameworks could be both issue focused (e.g. Alliance for Water Stewardship, Global Living Wage Coalition) and holistic (e.g. GRI, Future-Fit Business Benchmark).
As noted in b. above, companies should report how they are measuring the use and effectiveness of their policies, as well as how they are improving the outcomes where they fall short of expectations.
As noted in a. above, companies should describe how and where all non-financial impacts of their business model occur. Naturally some of these will present greater material risks to a company than others and it is reasonable for a company to prioritise these. However, that should not mean a company can ignore its other impacts (they may still be material to the environment or affected community).
See answer to a.
See answer to a.
If a company wishes to omit information then it should note that it has done so. However, it should then be assumed that the company is doing nothing to mitigate this particular impact / risk such that there is a strong disincentive to taking this approach.
1 (best option)([ID68])
2 (second preferred option)([ID69])
 
 
 
 
The guidelines should seek to provide the key principles for reporting of KPIs alongside narrative description and relevant financial information, but reference best in class external frameworks for detailed guidance. Such frameworks could be both issue focused (e.g. Alliance for Water Stewardship, Global Living Wage Coalition) and holistic (e.g. GRI, Future-Fit Business Benchmark).
1([ID104])
The guidelines cannot reasonably expect to cover all issues like this in sufficient, up to date detail to provide meaningful guidance. Rather, they should highlight key issues such as this and point to existing best in class guidance from external issue experts. The guidelines should encourage all companies to explain how they are addressing each issue - and any others pertinent to them.
2([ID81])
6 (most in line)([ID85])
4([ID83])
3([ID82])
5([ID84])
1 (least in line)([ID80])
N/A
The guidelines should help companies understand the key requirements and best practice for non-financial reporting rather than seek to introduce yet another standard. It should therefore guide companies towards market-leading standards and frameworks such as those listed or produced by NGOs such as GRI and the Future-Fit Foundation.
Consider all companies([ID98])
We believe the behavioural characteristics of all companies are the same if they are to be truly sustainable, irrespective of size or sector (zero Carbon emissions, all workers paid a living wage, etc.) The scale of issues and resources available to tackle them will be vastly different between companies, but the guidelines will be more helpful if they offer a homogenous approach suitable for all.
Yes([ID96])
Yes([ID96])
We use the Future-Fit Business Benchmark.
Don’t know / no opinion / not relevant([ID98])
Whilst board diversity is very important and positive for any company, we do not believe that definitive targets for different groups can either be scientifically defined or can be correct in one and all circumstances. As such, we fully encourage openness on board diversity policy but steer away from defining boundaries or limits on what diversity means.
a private individual(public-replying-as)
Zaiella AISSAOUI
 
 
 
 
 
 
 
 
France([ID30])
 
Insurance([ID9])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
7([ID23])
5([ID21])
6([ID22])
8([ID24])
4([ID20])
2([ID9])
3([ID10])
1 (least important)([ID8])
 
 
The shareholders([ID16])
 
they have the major interest to read this information
1 (least important)([ID19])
6([ID36])
5([ID35])
7 (most important)([ID37])
3([ID33])
2([ID32])
 
 
it is necessary to understand the impacts of the company's activity to be sure that it will be on line with the values of people who want to invest or buy products
4([ID54])
they could explain thier positions and choices of development
 
 
 
 
 
 
 
 
 
 
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
it must be concrete and not general standard only
3([ID106])
it is necessary to have a few information about the consequences from the supply chain and to identify the impacts of any major decision on the supply chain
2([ID81])
4([ID83])
6 (most in line)([ID85])
5([ID84])
3([ID82])
1 (least in line)([ID80])
nothing
just with reference not to do the same document
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
it is necessary to adapt the document according the targeted companies
Don’t know / no opinion / not relevant([ID98])
 
 
Don’t know / no opinion / not relevant([ID98])
nothing to report
 
an organisation or a company(organisation-replying-as)
 
Cefic - The European Chemical Industry Council
 
Yes(yes-transparency-register)
64879142323-90
Industry association([ID9])
 
 
 
Belgium([ID22])
 
Other([ID7])
The chemical industry - manufacturing
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
7([ID23])
1 (least important)([ID8])
9 (most important)([ID25])
3([ID10])
4([ID20])
5([ID21])
6([ID22])
2([ID9])
Confidential business information
Other([ID112])
The main audience may depend from sectors and companies. It is for them to determine.
All of the above could be considered important audiences for the non-financial statement. This will be different from one company to another, depending on their size, sector, the nature of the business, challenges and risks it faces and corporate culture. It is for each company to determine who to target the statement at.
4([ID34])
5([ID35])
3([ID33])
7 (most important)([ID37])
6([ID36])
2([ID32])
 
 
What makes a piece of information relevant differs between companies based on their business environment, sector, and corporate culture. Companies should have flexibility to decide this. It is important that the management of the company finds the information useful and can embed it in the overall strategy, to increase performance and development of the company and its competitiveness.
1([ID48])
Companies differ in how they disclose non-financial information and different users of the information have different needs. The Guidelines can therefore only be useful if they set out general principles. If detailed, they would lack necessary flexibility. It is then for each company to find and detail the solutions adapted to them. It is also necessary to allow evolution of these systems.
The best way to treat this matter in the Guidelines is to avoid prescriptive and specific texts. There are different ways of describing this, therefore flexibility is needed for companies to do this in the way that suit them. In addition, examples may be provided in the Guidelines.
see a
see a
see a
Here too, flexibility should be considered. It is for companies to decide which KPIs they want to use, as the most relevant KPIs will differ from one company/sector to another. In addition, examples of systems including KPIs may be provided in the Guidelines, such as the GRI (Global Reporting Initiative).
see a
see a
see a
see a
see a
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
see 5.e
1([ID104])
The Directive already states a number of topics for disclosure. Companies need freedom and flexibility to inform on the issues which are relevant to them and their stakeholders. Additional specific issues, such as responsible sourcing of minerals, should therefore not be included in the Guidelines.
1 (least in line)([ID80])
2([ID81])
6 (most in line)([ID85])
4([ID83])
5([ID84])
3([ID82])
NA
In the chemical sector many companies already use national/EU/international frameworks and should be able to continue. There is no need for the Guidelines to install a new framework, or give a preference to which frameworks companies can use. It is for companies to decide. However, the Guidelines may show on how to use existing frameworks to comply with law and avoid reporting twice.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
No, since the Guidelines should only address the requirements of the companies under the scope of the Directive.
Don’t know / no opinion / not relevant([ID98])
 
 
Don’t know / no opinion / not relevant([ID98])
Cefic AISBL does not deal with this issue.
 
an organisation or a company(organisation-replying-as)
 
VERBUND AG
 
Yes(yes-transparency-register)
09571422185-81
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Austria([ID21])
 
Other([ID7])
Energy
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
6([ID22])
5([ID21])
4([ID20])
2([ID9])
3([ID10])
7([ID23])
8([ID24])
 
 
The investment community in a broad sense([ID17])
 
The investment community also includes existing shareholders. New financial tools such as green bonds are emerging in the financial market. This can also broaden the group of investors for companies and could be an advantage for enterprises. These investors should be provided with all essential information. No single report will be suitable for all users of information.
3([ID33])
6([ID36])
2([ID32])
4([ID34])
5([ID35])
7 (most important)([ID37])
 
 
The non-financial statement will show the integrated approach the management has chosen to manage current and future risks.
1([ID48])
Companies that have already taken a decision on which guidelines to follow in their non-financial reporting will not be willing to adopt new directives. New detailed instruction would not support the comparability of data.
 
 
 
 
 
 
 
 
 
 
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
Comprehensive standards for sustainability reporting have already been elaborated, including all sorts of possible stakeholders. One new standard will not improve the level of reporting. A good approach would be to address existing standards and to work out the essence of them to be able to provide a baseline for non-financial reporting.
1([ID104])
See Q6.1
2([ID81])
4([ID83])
6 (most in line)([ID85])
3([ID82])
5([ID84])
1 (least in line)([ID80])
-
See Q6.1
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
Of course, guidelines have to take the size of companies into account. It should be the target that the companies under scope of the directive have a suitable paper to work with. Adjustments for other companies can be made later on.
Yes([ID96])
Yes([ID96])
We use the GRI-Guidelines G4 of the Global Reporting Initiative.
Yes([ID96])
Diversity of the board, regarding gender, know how, expertise regarding ecological and social aspects.
 
an organisation or a company(organisation-replying-as)
 
AECA- Spanish Accounting and Business Administration Association (AECA, Asociación Española de Contabilidad y Administración de Empresas)
 
No(no-transparency-register)
 
Think tank([ID12])
 
 
 
Spain([ID48])
 
Accounting([ID4])
Auditing([ID6])
Reporting/Communication([ID4])
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
5([ID21])
3([ID10])
8([ID24])
1 (least important)([ID8])
2([ID9])
4([ID20])
7([ID23])
6([ID22])
9 (most important)([ID25])
Interoperability from digital perspective
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
In modern societies, the role of different actors interacting with special interest firms can be highly interchangeable. Suppliers can become shareholders, those can also be customers or employees; the role of local communities and the public opinion is essential for the sustainability of such entities. So, even thought that the firms should be able to respond to particular information needs, it i
4([ID34])
6([ID36])
3([ID33])
2([ID32])
7 (most important)([ID37])
5([ID35])
 
 
In the era of Big Data, and from this type of firms, the priority should be to provide a general, comprehensive, detailed and digitally supported material about all relevant facts related to each corporation. This priority should empower each type of stakeholder to perform its pertinent analyses and actions.
5([ID55])
After several decades of voluntary and unstructured non-financial reporting, academic and professional evidence point out the lack of efficiency of such flow of information, due to unstructured reports, heterogeneity in formats, impossibility to compare firms or to follow them across time. Concreteness is mandatory at this stage, supported by digital standards.
Relevant and concrete descriptions of key aspects as: general environment(economic, socio-technical and political matters) along with specific information on key forces around the firm (main customers/suppliers, the identification of principal competitors). A typical definition of mission/vision plus current and prospected presence in markets/geographic locations.
Some disclosure of key strategic goals and policies regarding economic, social and environmental behaviour, if applicable, to targets.
Some information about internal control, specifically if it is externally assured, and the scope of these assurances on non-financial reporting and the responsibility of the corporate governance bodies with it.
Some information on the detailed structure of the corporate group, along with strategic alliances and joint ventures. Additionally some details on how the corporation engages with professional institutes, corporate associations, etc.
Our association proposes a detailed set of KPIs supported by XBRL, a selection of KPIs which an independent industry and national contexts. Our proposal for the guidelines is an authorized list of high-quality KPIs associated with respected international bodies and consortia.
Specific comments strongly connected to the values of KPIs, following the style of notes to financial statements.
A set of comprehensive KRIs (key risk indicators), in accordance to internationally recognised risk frameworks, with sufficient aggregates values, with relevant thresholds. Accompanying information is strongly required here, in order to guarantee an adequate understanding of these metrics by all stakeholders.
A map of KPIs versus key stakeholders
Connected to the previous section, but providing mitigation plans or actions and their corresponding results
A clear statement regarding why each specific section or KPI is not disclosure, clarifying in each case which information is not available due to materiality, technical measurements issues or actual competitive reasons.
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
 
 
The lack of effectiveness of unstructured non-financial reporting leads us now to require more concrete frameworks. Comparability, along with the application of digital formats, involves a certain degree of standardization. In the other hand, there should be some acknowledgement of previous good practices and existing high-quality frameworks for KPIs.
5([ID108])
To be sustainable, a corporation must ensure, to a reasonable extent, that its precedents in the value chain are all under certain principles of respect for human rights and the environment. Due to their gravitational position, these firms are destinated to play a key role in that task, expanding sustainability all along the supply chain.
2([ID81])
3([ID82])
5([ID84])
4([ID83])
6 (most in line)([ID85])
1 (least in line)([ID80])
none
There are several other international and sectorial frameworks, along with the before mentioned ones, from which the non-financial statement can benefit. The guidelines should explain to what extent a given framework is suitable for that document.
Consider all companies([ID98])
Yes, the content should be more detailed for big corporations, as it occurs in the financial reporting arena
Yes([ID96])
Yes([ID96])
Global Reporting Initiative v3,1 plus our proposed Integrated Scoreboard (is.aeca.es/en)
Yes([ID96])
This is a key issue in modern corporations, due to the fact that diversity in boards is relevant for the ethics of the firm and also for its efficiency, according to both academic and professional evidence; hence, that aspect should be well detailed, in particular, by citing relevant examples of high quality KPIs on that matter.
a private individual(public-replying-as)
Marta Fernandez
 
 
 
 
 
 
 
 
Spain([ID48])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
5([ID21])
8([ID24])
1 (least important)([ID8])
3([ID10])
2([ID9])
4([ID20])
7([ID23])
6([ID22])
Stakeholder inclusiveness
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
A non-financial report is a valuable tool to foster stakeholder dialogue, to easily and efficiently share information, ideas, and expertise across the company and with relevant stakeholders to map their ‘reasonable’ expectations and define what is material to them.
2([ID32])
5([ID35])
6([ID36])
4([ID34])
7 (most important)([ID37])
3([ID33])
 
 
A non-financial report is a valuable tool to integrate information in an efficient and effective way in order to tackle emerging risks, future challenges and opportunities. It allows a company to define its impact and make better decisions on issues that are important to both stakeholders and the company.
4([ID54])
Two issues have a negative impact on non-financial reporting: (1) an ever-growing number of non-aligned guidelines or standards, and (2) their impact on comparability. A sectoral focus would allow companies to select, compile and report data in a manner that is comparable to their sector and relevant to their consumers or stakeholders. In fact, the GUIDELINES should also focus on public agencies.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
In all cases, definitions and descriptions should be fully aligned with existing frameworks for consistency purposes.
1 (best option)([ID68])
 
 
 
2 (second preferred option)([ID69])
The GUIDELINES should include a comprehensive list of sectoral KPIs, addressing concrete matters or issues
Most non-financial reporting KPIs are focused on qualitative rather than quantitative data. Companies find it hard to define measurable KPIs, and existing international guidelines and/or standards (with few exemptions), generally focus on one of three ESG issues. The GUIDELINES should therefore include a comprehensive list addressing concrete matters or issues
4([ID107])
Guidance on specific sectoral issues can provide a baseline for companies to benchmark good practices within their sector, to assess risks (both operational and supply chain related), and to promote supply chain engagement by focusing on issues that are important to their specific sector.
1 (least in line)([ID80])
3([ID82])
5([ID84])
2([ID81])
6 (most in line)([ID85])
4([ID83])
The GUIDELINES should include detailed sectoral supplements
In many countries, large public-interest entities are already required and have been reporting for several years on non-financial issues based on existing frameworks. In the interest of consistency and comparability, the GUIDELINES should explain how the content produced in the context of these other frameworks is aligned with the EU-approach on non-financial reporting.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
Yes, the GUIDELINES should include other companies and public agencies in order to facilitate supply chain engagement, for example. At present, smaller service providers of large public-interest entities have difficulty complying with requirements imposed by existing frameworks, such as environmental and quality certifications, human rights, etc., to be able to participate in tenders.
Yes([ID96])
Yes([ID96])
Global Reporting Initiative
No([ID97])
We understand that talent management and equal remuneration for men and women are at present more pressing issues than diversity.
 
an organisation or a company(organisation-replying-as)
 
Hööks Hästsport AB
 
No(no-transparency-register)
 
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Sweden([ID49])
 
Other([ID7])
Selling items to end consumers through stores and e-commerce
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
5([ID21])
6([ID22])
3([ID10])
9 (most important)([ID25])
2([ID9])
7([ID23])
8([ID24])
4([ID20])
 
 
Users of information with an economic interest, such as suppliers, customers, employees, etc.([ID18])
 
The statement is of interest to all people/organizations that are in contact with our company, and the interest for such information will for sure increase in the future. It is also important for us an company to see how we perform and measure how we gets better over time.
3([ID33])
2([ID32])
4([ID34])
7 (most important)([ID37])
6([ID36])
5([ID35])
 
 
The statement is of interest to all people/organizations that are in contact with our company, and the interest for such information will for sure increase in the future. It is also important for us an company to see how we perform and measure how we gets better over time.
5([ID55])
With a high level of detail/prescription the guidelines will be easier to follow. A set and detailed framework for the reporting would help companies to gather the data and to present a complete statement without a lot of consultants involved.
 
 
 
 
 
 
 
 
 
 
 
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
Clear definitions of the KPIs are important for easier gathering of data and for comparison. Some sort of flexibility of what KPIs to include should be possible when all companies are some what different.
No opinion([ID109])
No
6 (most in line)([ID85])
2([ID81])
3([ID82])
4([ID83])
5([ID84])
1 (least in line)([ID80])
No
If the guidelines have information and detailed solutions it is easier to follow and other guidelines is not neccesary also to learn.
Consider all large companies([ID97])
No
Yes([ID96])
No([ID97])
 
Don’t know / no opinion / not relevant([ID98])
No
 
an organisation or a company(organisation-replying-as)
 
Smart Kolektiv
 
No(no-transparency-register)
 
Non-governmental organisation([ID11])
 
 
 
Other country([ID53])
Serbia
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
4([ID20])
9 (most important)([ID25])
5([ID21])
2([ID9])
3([ID10])
6([ID22])
7([ID23])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Understandably investors are very interested in all aspects of potential investments, but information on social, economic and environmental impacts should be available to all stakeholders to provide adequate decision making. (For example,consumers may not want to buy products or services of socially unaware companies) Reports should provide comparable and understandable information forall of them
2([ID32])
4([ID34])
5([ID35])
7 (most important)([ID37])
3([ID33])
6([ID36])
 
 
Reporting on non financial impact should be a tool to encourage and enhance the development of CSR practices, as well as to indirectly minimize negative impact of business, by representing a potential source of a bad publicity, and potential threat of a lawsuit. Hence, information is material if provide an accurate description of positive and negative impacts of the companys' performance.
4([ID54])
Guidance should be detailed to the extent that companies cannot bypass to disclose to the negative impacts.
Brief description that includes information on ownership, revenue structure, organizational infrastructure, strategy, vision, mission...
Very important element of the report. Should provide the list of all companys' policies sorted by important business functions, with clarification if they comply with the law, international declarations, or if they meet certain criteria (for example concerning human rights, antitrust...)
Information on does company conduct due diligence, how does it audit this process, and what stakeholders are included.
This part should provide the companys' definition of the stakeholders, and comprehensive list of all categories of stakeholders that are included in the process of decision making, then stakeholder engagement methods and activities for the reporting period, the effects of those processes, and implementation of the recommendations.
Definition of KPIs, list and methods for monitoring and evaluations.
Disclose on changes that occured in indicators defined in those policies, and implemented activities that lead to the changes.
Company should disclose on identified potential or actual risks
Emphasis should be on balance between positive and negative impacts.
The company has to constantly implement the process of identifying potential adverse impacts. When risks are recognized, it is especially important how they are communicated to all interested parties, and what company is currently doing for prevention.
Incidents or potential risks with serious consequences for the environment or community.
2 (second preferred option)([ID69])
 
 
 
1 (best option)([ID68])
The Guidelinies should include a comprehensive list of KPIs, general and sectoral, but not too extensive, and should also provide references to KPIs proposed by other frameworks.
List of KPIs, with a very concise and not too extensive requests will ensure comparability between reports, and references to the other reports will facilitate the process for those companies that already have reports on sustainability.
3([ID106])
The sectoral guidance would be the best option, but bearing in mind the scope of work for creating guidelines for a variety of sectors, the general principles will suffice, and later they can be amended.
1 (least in line)([ID80])
2([ID81])
4([ID83])
3([ID82])
5([ID84])
6 (most in line)([ID85])
The GUIDELINES should explain how content produced in the context of other frameworks could be presented in the comparable way with concise, short information.
The main point is that non financial statements should be short, to the point and comparable, and the guidelines should ensure that.
Consider all companies([ID98])
No, guidelines should be universal. It is acceptable if SME could not provide answers to all requests. Those requests should be pronounced.
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
Description of the current state concerning board diversity and goals and activities to achieve progress.
 
an organisation or a company(organisation-replying-as)
 
Rabobank
 
No(no-transparency-register)
 
Other([ID14])
cooperative bank
 
 
The Netherlands([ID51])
 
Banking([ID8])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
3([ID10])
4([ID20])
2([ID9])
6([ID22])
5([ID21])
7([ID23])
8([ID24])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Non-financial reporting serves a broad audience and covers a company's overall reporting on its responsibilities
3([ID33])
2([ID32])
4([ID34])
7 (most important)([ID37])
6([ID36])
5([ID35])
 
 
Currently a company's impact is most valuable to be reported upon for broad stakeholder groups
2([ID49])
More geared towards general principles as they give the opportunity for individual firms to specify their specific case and activities
Business model as part of a firm's value creation model is key
Brief evidence how company has policies and procedures in place is valuable
Only reporting if audited
only mention position in supply chain
Broad coverage on KPI's as they are evidence for company's non-financial goals
mention issues and engagement
Mention key risks
Detailed reference of company's impact is desirable
Brief mention of this
Include brief disclaimer
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
KPI's vary and differ by definition in firms, reporting should reflect this
3([ID106])
As sectoral approach is more easily comparable than individual KPI's, guidelines can be provided
2([ID81])
3([ID82])
6 (most in line)([ID85])
4([ID83])
5([ID84])
1 (least in line)([ID80])
-
As there are so many frameworks currently, it is vital to show where they interact and overlap. Also referring is useful as this avoids doing the same work twice.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
General content applicable to broad categories of companies will allow for fastest adoption
Yes([ID96])
Yes([ID96])
IIRC reporting framework and GRI G4 reporting guidelines
Yes([ID96])
This is an increasingly relevant social indicator where a lot of work remains to be done
 
an organisation or a company(organisation-replying-as)
 
Repsol
 
Yes(yes-transparency-register)
6924039519702
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Spain([ID48])
 
Other([ID7])
Oil and Gas
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
3([ID10])
4([ID20])
9 (most important)([ID25])
6([ID22])
1 (least important)([ID8])
2([ID9])
5([ID21])
7([ID23])
An important aspect of disclosure is “Transparency”, which is broader than, but is inclusive of “understandability” and “fairness and balance”, as listed. In the Oil and gas industry guidance on voluntary reporting, IPIECA, API and IOGP have adopted 5 general reporting principles from the World Resources Institute “The Greenhouse Gas Protocol - A Corporate Accounting and Reporting Standard”. These are Relevance, Transparency, Consistency, Completeness and Accuracy. IPIECA, API and IOGP believe all of the aspects listed in this question are covered by these 5 principles, including burden which should be an outcome of applying appropriate processes that meet the principles.
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
In general, all users who have interest on the sustainability performance on the company should be the target. Likewise, investors are a very relevant stakeholder.
2([ID32])
4([ID34])
3([ID33])
6([ID36])
7 (most important)([ID37])
5([ID35])
 
 
The first goal is to account on the sustainability performance and targets as part of our understanding on how sustainability is focus on. The second one, to explain how the company is managing its risks and finally to provide useful information for the shareholders/ investors' decision making process
3([ID50])
The Directive 2014/95/EU already lists non-financial issues in clause 7 that should be considered by a reporting company. There already exists considerable guidance internationally on reporting these issues. It is therefore more appropriate to set out general principles and explain how these can be properly achieved (with examples) than duplicating detailed guidance issue by issue or by sector
Even within a sector, business models differ significantly. For the petroleum industry (for example) a company's environmental and social issues will be affected by location and nature of assets, ownership and maturity of operations. Therefore flexibility is needed for reporting business models appropriate to these differences. Thus broad guidance on intent with examples should be sufficient.
It is generally important to report on company policies relevant to the issues that are material to report. However, policies and processes do not change significantly from year-to-year so it is usually only necessary to state how the information can be accessed and report any updates. To this extent, guidance can be flexible and brief.
To meet policies and regulatory requirements, companies will have due diligence and related management processes, and this information would normally be reported in relation to specific material issues. Guidance can be combined with that for Policies and can be brief, with flexibility to report qualitatively or provide quantitative information if appropriate to the issue.
In the context of Directive 2014/95/EU and the addition of Article 29a to Directive 2013/34/EU, 1d concerns reporting of principal risks including in its business relationships, but also products and services. This needs to be determined by companies, not guidelines, as the risks will vary greatly. The guideline could elaborate on how to report in general with examples.
KPIs need to be useful, and guidelines often narrowly constrain their value. There is also an extensive choice already available (e.g. GRI, OECD). It is recommended that guidance is not specific, and that companies determine their own KPIs appropriate to the maturity of their management systems for each material issue. The Guideline could focus on need for and how to set KPIs, not what to set.
For issues that are material for reporting, outcome of policies should be reported together with access to information on the policies and associated processes, including any KPIs, as noted in b, c and e above. Outcomes can include plans for the future, including objectives and targets. Guidance needs to be provide flexibility to be commensurate with the priority of the issues.
As noted in d. above, in relation to Article 29a of Directive 2013/34/EU, companies need flexibility on how to report their main risks and this should be aligned with their materiality process for non-financial reporting. Environmental risk reporting is already a requirement for many company's statutory reporting so the Guideline should be brief and flexible to incorporate existing approaches.
Reporting of qualitative and/or quantitative impacts related to company activities is well established for the issues that are commonly material across the petroleum sector. Guidance on impacts, such as greenhouse gas emissions or injuries, is already extensive and internationally standardized. Generic guidance on impact reporting may be useful but duplicating specific guidance should be avoided
Impacts related to material issues should be reported whether beneficial or adverse, without bias, otherwise the principles of relevance, transparency and completeness would not be met. There should be no need for separate guidance on adverse impacts, other than to clarify that such impacts are reportable under h. above.
Companies need to have flexibility to use judgment on whether sensitive information should not be disclosed in a public non-financial report. Non-disclosure may be for legal reasons, lack of reliable information, or due to third-party / governmental constraints. If possible, companies should explain any omissions. Typically only brief guidance is required (see, for example, GRI).
2 (second preferred option)([ID69])
 
 
1 (best option)([ID68])
 
 
There is already a wide choice of documented and standardized KPIs available, both generic and sector specific. It is important to provide flexibility for companies to set appropriate KPIs at a corporate or local level based on the importance, maturity and specificity of a material issue. To enhance comparability, companies should select established KPIs (ideally international), if available.
1([ID104])
For many sectors, guidelines already exist at an international level (e.g. from GRI), which is appropriate for sectors whose operations are global with partnerships not confined to the EU. For the petroleum sector, IPIECA, API and IOGP established non-financial reporting guidance in 2005, and continue to improve this guidance (editions 2005, 2010, 2015) with stakeholder input, supply chain, value
1 (least in line)([ID80])
2([ID81])
6 (most in line)([ID85])
3([ID82])
5([ID84])
4([ID83])
Align - the Guidelines should aim to align terminology, principles and processes with international guidance, and avoid duplication if detail can be referenced.
It is already a burdensome challenge for companies to align their reporting with the existing multiplicity of frameworks. Greater convergence at an international level is clearly helpful for all reporters and audiences. In meeting the requirement of Directive 2014/95/EU to produce Guidelines, it is recommended that avoidance of reinvention or duplication should be a principle of the project.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
No, the Guidelines are a requirement of Directive 2014/95/EU. If a broader focus on non-financial reporting was intended, this could more easily be achieved by simple adoption of an existing international framework. The need for the Guideline is only due to the existence of the Directive. An out-of-scope company can meet the intent of the Directive by applying existing international guidance.
Yes([ID96])
Yes([ID96])
We are using mainly the global reporting initiative GRI & taking into account the IPIECA guidelines
Yes([ID96])
The Directive already provides requirements on information related to board diversity. The general guidance on policies, due diligence and policy outcomes should be sufficiently applicable to board diversity, employee diversity and any other aspect of diversity which is material for reporting by the company. Specific additional guidance is therefore unnecessary.
 
an organisation or a company(organisation-replying-as)
 
ANEC, the European consumer voice in standardisation
 
Yes(yes-transparency-register)
507800799-30
Consumer organisation([ID8])
 
 
 
Belgium([ID22])
 
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
7([ID23])
3([ID10])
9 (most important)([ID25])
2([ID9])
1 (least important)([ID8])
4([ID20])
5([ID21])
6([ID22])
8([ID24])
VERIFIABILITY
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Information would need to be made available to both company stakeholders and general public to foster informed decision making at all levels when taking good account of the impacts companies have on society. To ensure reliability of the information there need to be controls from authorities in place as well.
2([ID32])
4([ID34])
5([ID35])
6([ID36])
1 (least important)([ID19])
3([ID33])
7 (most important)([ID37])
Necessary to assess the performance of the company compared to the performance of other, similar companies using appropriate benchmarks
Some of the answers (as in Q1) are equally important! The need to put the features in order biases the judgement. The most important features for the purpose of non financial information statements are: the understanding of the impacts of the company's activity and the assessment of the company performance compared to others, by use of benchmarks
5([ID55])
If guidelines do not provide detailed requirements and choice is left to companies, comparability (one of main aims of the guidelines according to Art. 2 of the Directive) isn't achieved. A European approach on corporate accountability reporting should therefore be started in the guidelines.A first set of requirements and indicators could be gradually expanded (more detailed later). See also Q8.1.
It is of minor importance because this will be essentially of qualitative nature and will be difficult to link to performance and will be difficult to verify or to objectify.
It is of minor importance because companies are free to tell any story which may not be more than hot air. As an example, Volkswagen claimed in its Sustainability Report 2014 that their aim is to become the most sustainable car manufacturer of the world – this was impressing but apparently nothing else than nice words. Similar things could be told about many other companies.
It is of minor importance because due diligence is essentially a management process which can, however, be linked to ANY performance goal. For the public it is not relevant how a company is managed and which instruments it uses to achieve certain goals. It is only relevant whether the the public expectations are met, i.e. which performance is achieved and which requirements are met.
It is undoubtedly important that a company establishes sustainability demands on its suppliers and it is, of course, useful to inform the public about specifications imposed on suppliers such as Restricted Substance Lists (RSLs) disallowing the use of certain chemicals or provisions asking compliance with certain sustainability specifications.
KPIs are at heart of any meaningful sustainability report and, thus, also crucial as regards the guidelines. Given that KPIs should be relevant/material, comparable (i.e. capable of benchmarking), reliable & verifiable they must be precisely defined similar or even better compared to current practices in the field of EMAS (sector reference documents) including precise measurement and verification
The outcome is, of course, important but only if linked to clear-cut measures of performance including benchmarks. Otherwise the result will be reports with lots of gibberish (see answer to b.)
It is difficult to imagine any rules forcing companies to be honest.
It is difficult to imagine any rules forcing companies to be honest and give an objective an balanced assessment.
It could be required that companies must report all activities which have led to damages to people or environment including costs involved from a certain amount onwards. Also companies should be obliged to report on any public initiative challenging practices of the companies (such as selling pesticides that could damage bees) and responding to concerns (e.g. publishing all confidential evidence).
 
 
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
Existing frameworks may be used as source of inspiration,but it’s key to establish a European set of indicators to cover broad range of sustainability subjects.Indicators must be relevant,measurable,robust,comparable & fit for benchmarking.It is key these are generic,but also sector specific or even sub-sector specific.Indicators can partly be taken from EU BREF (BAT) or EMAS sector ref. documents
5([ID108])
As pointed out above sector specific approaches are highly relevant. Although it is not expected that the first edition of the guide can include all sector specific provisions – rather a set of rules will have to be established in the course of years – it is important to identify the issues to be covered in future.
5([ID84])
1 (least in line)([ID80])
4([ID83])
3([ID82])
2([ID81])
6 (most in line)([ID85])
Include a European methodology to develop sector specific KPIs based on consensus among interested parties. Existing frameworks may be used as source of inspiration, but it is key to establish a European set of indicators to cover a broad range of sustainability subjects. Such indicators must be relevant, measurable, robust, comparable and fit for benchmarking. It is important these are not only generic but also sector specific (e.g. the fleet consumption of cars) or even sub-sector specific (e.g. energy intensity of the production of 1 tonne of steel). Such indicators can partly be taken from EU BREF (BAT reference) documents or EMAS sector reference documents. Existing guidelines such as the ones prepared by the Global Reporting Initiative (GRI) are very popular among big corporations because their significance is very limited. The indicators are neither comparable nor capable of benchmarking. Nobody is served with indicators developed for the purpose of having indicators which do not allow an assessment of the performance of enterprises and which are hardly anything else than a nice decoration of reports. KPIs must be precisely defined similar or even better compared to current practices in the field of EMAS (sector reference documents) including precise measurement and verification protocols (similar to e.g. provisions for energy label criteria). In many cases this will mean sector specific indicators although there will be also generic indicators in non-environment related areas (work place, human rights). Initially a matrix should be established on indicators to be developed in a generic fashion and on a sector basis. The indicators by the GRI should not be taken over as they are mostly not capable of benchmarking and deliver numbers of dubious benefit … A broad discussion on useful reporting requirements and key performance indicators should take place in a relevant democratic multi-stakeholder platform.
The new guidelines need to aim at increasing transparency on the basis chosen for the declarations. Else,declarations will continue being used for marketing purposes with companies choosing to declare only what displays best for their image.Inspiration can be taken from EMAS sectoral documents & ISO 14031 on environmental performance evaluation. A democratic discussion on requirements is needed.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
This seems a rather theoretical question as the scope of the Directive is not based on areas of activities but on size and legal status. In practice, a differentiation will be not relevant. Why should an indicator of, say, energy intensity of the production of 1 ton material be different for a company outside the scope of the directive?
Don’t know / no opinion / not relevant([ID98])
 
 
Yes([ID96])
It is already widespread practice to report on the gender distribution and it should become practice to be transparent about board diversity policy in general.
an organisation or a company(organisation-replying-as)
 
Arla Foods amba
 
No(no-transparency-register)
 
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Denmark([ID27])
 
Other([ID7])
Dairy industry
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
5([ID21])
2([ID9])
7([ID23])
4([ID20])
3([ID10])
6([ID22])
9 (most important)([ID25])
1 (least important)([ID8])
?
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Each company must make its own focus.
4([ID34])
3([ID33])
2([ID32])
6([ID36])
7 (most important)([ID37])
5([ID35])
1 (least important)([ID19])
The Impact of a given activity and the ability of a given activity to create value for multiple stakeholders
Depends on materiality analysis of the company - could relate to social, economic or environmental issues
1([ID48])
If the guidelines are too prescriptive they risk to become irrelevant for a given company.
Important to describe the vision and the purpose of the company - what do they do for whom and why. Important to describe the companys value chain. Important to describe link between strategy and corporate responsibility.
Policies are internal guidelines transforming ethical guidelines into practice - would be great with examples of what it could look like.
Describe what is meant by due dilligence and provide examples of what it could look like.
Describe what is meant by business releationships and provide examples of what it could look like. Could be different from business to business
Would be great with examples of both economic, social and environmental KPI's. Provide guidance on how many KPIs make sense. Companies typically have a lot of KPI's - but which are typically the most relevant?
Describe what is meant and provide examples.
The number of risks a company could describe is endless - provide guidance to focus on risks of adverse effects on material issues and the areas outlined in the law
Describe what it is and provide examples. Guide companies to describe how they work with the impact of their activities - provide examples
 
 
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
Relevant KPIs differ from company to company. Important to have the most relevant KPIs. Important that they can refer to a global framework
3([ID106])
Overall sectoral guidelines is usefull - not too detailed - will quickly become irrelevant and bureaucratic
1 (least in line)([ID80])
4([ID83])
6 (most in line)([ID85])
3([ID82])
5([ID84])
2([ID81])
?
Many comapnies are reporting progress according to different international standards - important not to invent yet another standard - important to be able to reuse information or formats whenever possible.
Consider all companies([ID98])
No - if the guidelines are kept a little generic, this could help all companies
Yes([ID96])
No([ID97])
 
Don’t know / no opinion / not relevant([ID98])
Companies should report on general diversity - not necessarily on specific management levels - different companies have different owner structures that may have influence on diversity
 
an organisation or a company(organisation-replying-as)
 
respACT - austrian business council for sustainable development
 
Yes(yes-transparency-register)
599006221232-04
Non-governmental organisation([ID11])
 
 
 
Austria([ID21])
 
Reporting/Communication([ID4])
Corporate Social Responsibipty/ Sustainabipty([ID7])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
8([ID24])
9 (most important)([ID25])
2([ID9])
7([ID23])
3([ID10])
6([ID22])
5([ID21])
4([ID20])
 
 
All users of information (including consumers, local communities, NGOs, etc.)([ID19])
 
Q1: Usefulness: “Usefulness” begs the question: useful for what? We suggest changing this aspect to “decision usefulness.” Usefulness encompasses relevance, comparability, understandability, and reliability. Q2.1: In the interest of transparency, reporting companies should as far as possible make the non-financial statement accessible to and understandable for non-expert readers.
2([ID32])
3([ID33])
5([ID35])
7 (most important)([ID37])
6([ID36])
4([ID34])
 
 
Also consider information that: ● Links to financial condition of the company in context of politics & economic conditions where company operates. ● Provides insight into company’s future (i.e., forward-looking strategy, direction, & competitive position) ● Covers universal principles such as the UN Global Compact’s 10 Principles & SDGs, & applies widely accepted reporting standards
2([ID49])
The guidelines need to be flexible so that they can be adjusted to all companies which are diverse. Flexibility to exercise judgement is paramount to ensuring implementation (not box-ticking). It allows easier modification & update of guidelines. Still, they need to provide orientation and can not be abstract principles only. Companies need to be sure of what information shall be included.
 
 
 
 
 
 
 
 
 
 
 
1 (best option)([ID68])
 
2 (second preferred option)([ID69])
 
 
Rather than creating KPIs in its Guidelines, we suggest the Commission refers companies to the extensive lists of existing indicators such as SDG Compass, GRI Sustainability Reporting Guidelines, Sustainability Accounting Standards Board, etc.
1([ID104])
It is clear that sectoral guidance is the most useful kind, as it is tailored. We suggest the Guidelines disseminate sectoral standards done by GRI, SASB, and others, by referring companies to them. Beyond specific sectors, we recommend the GUIDELINES encourage reporters to align explicitly with universal principles such as those of the UN Global Compact & Sustainable Development Goals.
2([ID81])
4([ID83])
6 (most in line)([ID85])
3([ID82])
5([ID84])
1 (least in line)([ID80])
x
Leveraging existing, widely accepted resources rather than creating new ones. Hence, we recommend the GUIDELINES go beyond general inspiration but not so far as to become an exhaustive resource that repeats what is already contained in resources freely available in the market. Efficiently capitalizing on previous work done is paramount.
Focus on the requirements of the companies under the scope of the DIRECTIVE, but also propose best practice for other companies that prepare management reports([ID99])
At minimum, the Guidelines should focus on the companies under the scope of the Directive. However, if the Commission is able to guide companies outside that scope, that is welcome. Companies would surely benefit from it. In particular, if it is likely that the Directive’s scope will widen in a few years to include more and smaller companies, guidance now would help them prepare the transition.
Don’t know / no opinion / not relevant([ID98])
 
 
Don’t know / no opinion / not relevant([ID98])
-
 
an organisation or a company(organisation-replying-as)
 
Daimler AG
 
Yes(yes-transparency-register)
2349218828-41
Company, SME, micro-enterprise, sole trader([ID6])
 
 
 
Germany([ID31])
 
Other([ID7])
Automotive industry
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
1 (least important)([ID8])
8([ID24])
5([ID21])
9 (most important)([ID25])
7([ID23])
6([ID22])
3([ID10])
2([ID9])
 
 
The investment community in a broad sense([ID17])
 
The audience of the non-financial statement should be in line with the main audience of existing financial and non-financial reporting, namely shareholders and investors.
4([ID34])
6([ID36])
3([ID33])
2([ID32])
7 (most important)([ID37])
5([ID35])
 
 
The EU guidelines should make clear that the purpose of the required non-financial statement is not to replace existing non-financial reporting, but to harmonize it. It should therefore be in line with the main audience and features of existing non-financial reporting practices and limited to help shareholders and investors understand the company’s development, performance and position.
1([ID48])
We consider it neither desirable nor possible to define a detailed set of issues and key performance indicators that are both relevant and allow for true comparability with other companies even of the same sector. The EU guidelines should therefore relate to other frameworks and set out general principles and key ideas rather than defining general and specific sectoral issues.
Refer to reporting standards like GRI. It is important that wherever possible, the reference to already existing reporting can be used (e.g. Annual Report, Sustainability Report).We already provide a lot of material on non-financial matters, and this would allow us to make use of this. The definitions should be short and leave enough room for the specific company to Report what is most appropriate
Set out general principles and key ideas
Should not be part of guidelines
Should not be part of guidelines
Only general principles
Set out general principles and key ideas
Set out general principles and key ideas
Focus on development, performance and position
Focus on development, performance and position
Set out general principles and key ideas
 
2 (second preferred option)([ID69])
 
1 (best option)([ID68])
 
 
The output of a materiality analysis varies from company to company depending on sector, business model and other factors. It is therefore neither desirable nor possible to define KPIs that are both relevant and allow for true comparability. We believe that the most efficient means to achieve more transparency and comparability is the widespread use of acknowledged reporting standards like GRI.
1([ID104])
The relevance of an issue is defined by a company and its stakeholders. Any issue including supply chain management depends on various factors, e.g. a company's business model, product range or vertical integration.That's why materiality varies from company to company even from the same sector. The Commission should therefore relate to other frameworks instead of defining a detailed set of issues.
1 (least in line)([ID80])
2([ID81])
5([ID84])
4([ID83])
6 (most in line)([ID85])
3([ID82])
The most efficient means to achieve more transparency and comparability is the widespread use of acknowledged reporting standards like GRI. The Commission’s non-binding guidelines should therefore relate to other frameworks and set out general principles and key ideas rather than defining general and specific sectoral issues.
We believe that the most efficient means to achieve more transparency and comparability is the widespread use of acknowledged reporting standards like GRI.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
No, as they should be of principal nature.
Yes([ID96])
Yes([ID96])
GRI and UN Global Compact (Communication on progress)
No([ID97])
Existing laws and reporting standards are sufficient.
an organisation or a company(organisation-replying-as)
 
Financial Reporting Council
 
Yes(yes-transparency-register)
891654116196-35
Other([ID14])
Regulator
 
 
United Kingdom([ID52])
 
Reporting/Communication([ID4])
Not apppcable([ID8])
 
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
4([ID20])
3([ID10])
5([ID21])
1 (least important)([ID8])
8([ID24])
7([ID23])
2([ID9])
6([ID22])
Clear & Concise communication
The shareholders([ID16])
 
In our view, the primary audience for the annual report is shareholders as set out in the EU legal framework.
2([ID32])
7 (most important)([ID37])
3([ID33])
4([ID34])
6([ID36])
5([ID35])
1 (least important)([ID19])
See response to question 3.1 below.
In the context of the annual report, we believe that information is material when it is necessary for a shareholder’s understanding of the development, performance, position or future prospects of the business.
1([ID48])
In our view, principles-based guidelines are likely to result in more relevant reporting. This will provide flexibility for companies and Member States to implement the Directive in a proportionate manner. Detail is likely to result in reporting of boilerplate and immaterial disclosures rather than entity-specific relevant information.
Definition of business model, principles for key features of a business model – value creation, what the entity does and what makes it different from its competitors.
Principles for the type of policy information to be included. Communication principles to encourage concise descriptions, signposting to more detail on websites, entity-specific information.
Guidance on the considerations for a company in terms of its due diligence process. Identification of those elements of the process that the company may wish to report on.
Guidance to help companies go through the process of identifying key business relationships and report on those relationships that are relevant to the development, performance, position and future prospects of the business.
Principles for reporting of KPIs - where relevant, definitions, calculation method, purpose, data source, changes from previous years. Guidance on identification of material KPIs.
Guidance on how a company measures the outcome of the policies and links to KPIs. Guidance/examples on the type of reporting that would be relevant in respect of outcome.
Guidance on how a company might assess its risks, steps that a company may take to identify which of the risks are material to the business, elements of a principal risk disclosure e.g. description, mitigation.
Steps that companies may take to identify impacts e.g. guidance on how far in the supply chain the company should consider its impacts. Guidance on identification of material impacts.
Principles for good communication e.g. fair, balanced and understandable reporting. Guidance to help companies identify material adverse impacts.
Guidance on when disclosure may be seriously prejudicial and how companies may provide some high level disclosure that may be informative but may not lead to competitive disadvantage. See FRC’s Guidance on the Strategic Report for further information.
1 (best option)([ID68])
 
 
2 (second preferred option)([ID69])
 
 
The KPIs should be those that management use. These will be entity-specific and will require directors’ to apply judgement to determine which ones are key. Including a comprehensive list of KPIs could result in reporting of a long list of indicators that may not all be material or relevant to an understanding of the company.
1([ID104])
We consider that specific sectoral issues may be useful as examples to illustrate the application of principles. However, we believe that the use of examples should be limited as it would be difficult for guidelines to cover every issue in different sectors.
1 (least in line)([ID80])
6 (most in line)([ID85])
3([ID82])
5([ID84])
2([ID81])
4([ID83])
see response to question 8.1 below
We believe that companies and Member States should be given flexibility to use the framework that is appropriate to their particular facts and circumstances (e.g. local law). There are a number of frameworks relating to non-financial reporting and listing them all could be confusing.
Specific to the requirements of the companies under scope of the DIRECTIVE([ID96])
In our view the content of the guidelines should be similar for all companies but the guidance should be clearly differentiate between mandatory requirements in the Directive and non-mandatory guidance.
 
 
 
Yes([ID96])
We consider that the guidelines should cover the full content of the Directive and encourage companies to include a brief description of the boards policy on diversity. See UK Corporate Governance Code for further information.
an organisation or a company(organisation-replying-as)
 
Labour Behind the Label
 
Yes(yes-transparency-register)
946077021260-56
Non-governmental organisation([ID11])
 
 
 
United Kingdom([ID52])
 
Other([ID7])
Human Rights
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)(yes-contributions-publication)
9 (most important)([ID25])
8([ID24])
7([ID23])
1 (least important)([ID8])
4([ID20])
3([ID10])
6([ID22])
5([ID21])
 
 
Other([ID112])
All users of information (consumers, local communities, NGOs, etc.) including people directly affected by the activities of the business - the holders of human rights and their defenders.
The disclosure of non-financial information must be used to demonstrate social and environmental due diligence processes. One main audience for this data is people affected by business activity, who are protected by international rights, and their defenders. e.g.: Workers in a company supply chain protected by UN Guiding Principles on Business and Human Rights, and activists defending their rights
1 (least important)([ID19])
2([ID32])
4([ID34])
5([ID35])
3([ID33])
6([ID36])
7 (most important)([ID37])
Necessary to understand a company's due diligence process process to address adverse impacts on human rights holders and the environment.
Data should centre on demonstrating a company has met its due diligence with respect to non-financial responsibility i.e. social and environmental due diligence. Information must therefore focus on showing how a company evaluates impacts and risks of violating human rights or damaging environments, and how it addresses and mitigates these impacts and risks.
5([ID55])
Comparable data on specific measurable issues is essential for ensuring progress towards human rights aims - many companies are keen to see a level playingfield on this reporting. Due diligence process should be laid out based on specific criteria for identification, prevention and mitigation of impacts including in a company's supply chain, as provided in relevant UN and OECD standards.
Human rights and the social and environmental impacts caused by business are deeply embedded in business models. As part of the reporting, companies should evaluate the risks and impacts caused by their business strategy and value creation model. Companies should also report on the extent to which the duty towards mitigating this risk is shared across business departments, particularly purchasing.
Policy reporting should include: a description of overall aims and specific objectives of company's policies; an explanation of why these specific policies and objectives were selected and relevance to the company’s main risks; details on how policies are integrated and complied with throughout the organization and by key business relationships, including suppliers and subcontractors.
The guidance should cover: due diligence procedures to identify and address actual or potential adverse human rights and environmental impacts; description of those risks and impacts; action plans in place to prevent/mitigate risks or to remedy impacts, and outcomes of these plans, referencing relevant evidence. This process must include a company’s global supply and subcontracting chain.
A company must be clear on a) what its business relationships are, b) how due diligence is managed through these. For sectors dominated by global supply chains eg. garment: a) disclose the details of supply chains, including names, addresses and contact details of suppliers, subcontractors labour agencies, b) explain purchasing practices and assess potential adverse impacts of supplier choices.
The guidelines should encourage companies to develop and disclose KPIs relevant to salient/significant/severe human rights and environmental issues/risks in their business and global supply network. Guidelines should also state specific quantifiable KPIs that are common in a specific industry and recognized in sectoral standards.
To demonstrate the outcome of policies, companies should provide action plans with concrete goals and milestones realised in working to mitigate and re-mediate risks and adverse impacts.
Reporting on risk analysis should be detailed, sectoral, and comprehensive and should address all issues related in the directive. The analysis should explain the prioritisation of work in the company due diligence process.
Reporting should include clear details of what activity has been undertaken against each point of the company due diligence process. Description of impact of activity should also include an overview of interaction with rights holders affected by adverse human rights impacts and their feedback.
Reporting on impacts should include; Company self assessment of adverse impact of its activities, including purchasing practices impact in the supply chain; Reports from right holders, their defenders, and stakeholders on adverse impact of company activities and action to mitigate these; Information about complaints received through any complaint mechanisms the company has or participates in.
In these cases, a description should be provided of the category of data that has been omitted, and why the omission was necessary under specific grounds, which should be stated in the guidelines.
 
2 (second preferred option)([ID69])
1 (best option)([ID68])
 
 
 
In order to create a level playing field, and allow company best practice to be compared, the guidelines have to be specific on the information required. Guidance that advises reporting against a clear set of KPIs, general and sectoral, will create the framework needed to allow companies to disclose what could be considered sensitive, but essential information for ensuring human rights protection.
5([ID108])
Where there is existing sectoral requirements and guidance, it is in the interest of companies and stakeholders to have reporting that specifically covers issues comprehensively. Where there is different sectoral guidance, priority should be given to the more comprehensive. Ensuring NFR covers existing sectoral requirements decreases the reporting burden without reducing information disclosed.
5([ID84])
4([ID83])
6 (most in line)([ID85])
3([ID82])
2([ID81])
1 (least in line)([ID80])
None
It is necessary for companies to be aware of legislation on human rights broadly, including ILO conventions, and national labour law contexts, but the guidelines could usefully spell out relevant sections and recommend that companies report specific actions against these requirements. For purposes of human rights due diligence the UNGPs and OECD Guidelines should be used as the key frameworks.
Consider all companies([ID98])
Member states have the option to enlarge the scope of the directive (e.g. Denmark) so although the directive itself targets specific companies, others may need to use the guidance. The UN guidelines on business and human rights encourage all companies to report on human rights due diligence, and this EU guidance could support this effort.
Don’t know / no opinion / not relevant([ID98])
 
 
Don’t know / no opinion / not relevant([ID98])
No position.

No contribution to display no data

Rows per Page 
1
Are you replying as: an organisation or a company
First name and last name:  
Name of your organisation: Badai
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?)
Yes
If so, please indicate your Register ID number: 555632318779-09
Type of organisation: Other
Please specify the type of organisation: Political party
Type of public authority  
Please specify the type of public authority:  
Where are you based and/or where do you carry out your activity? Austria
Please specify your country:  
Field of activity or sector (if applicable): Not apppcable
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)
Yes, I agree to my response being published under the name I indicate (name of your organisation/company/public authority or your name if your reply as an individual)

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

Materiality/Relevance 4
Usefulness 3
Comparability 8
Avoiding undue administrative burden 1 (least important)
Comprehensiveness 5
Fairness and balance 7
Understandability 6
Reliability 9 (most important)
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?

All users of information (including consumers, local communities, NGOs, etc.)

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?

The civil society also has a legitimate interest in the information provided in the non-financial statements.

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 2
Relevant for shareholders or investors’ decision-making 4
Relevant for stakeholders in general 3
Necessary to understand the impacts of the company’s activity 7 (most important)
Necessary to understand the company’s development, performance and position 5
Necessary to understand how the company manages non-financial risks 6
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?

For a non-financial statement, the focus should not be on the company's or the stakeholder's financial interests, neither directly nor indirectly. It should focus on the impact _of_ the company's activity rather than influences _on_ the company's activity.

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)

4

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?

Presciption certainly has advantages in terms of comparability and understandability of non-financial statements. However, we do understand that some flexibility may be required.

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 2 (second preferred option)
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 1 (best option)
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)?

Selecting from a list of key performance indicators allows for higher comparability.

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)

4

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?

Some issues like this are quite important and there is a clear need for them to be communicated clearly.

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 4
The GUIDELINES should be complementary to other frameworks 3
The GUIDELINES should make reference to other frameworks where addressing concrete matters or specific issues 6 (most in line)
The GUIDELINES should get general inspiration from other frameworks 5
The GUIDELINES should explain how content produced in the context of other frameworks could be used in the non-financial statement 2
Other 1 (least in line)

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?

While the guidelines should certainly be independent from any other frameworks on any level, it may be helpful to refer to other frameworks. At this point, we would like to add that we would prefer binding rules over non-binding guidelines.

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?

Consider all companies

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?

Yes, to some extent. Different economic sectors would have quite different activities, which should be reflected in the guidelines.

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

Don’t know / no opinion / not relevant

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?

Yes

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?

Board diversity is an important issue, which should be appropriately covered in non-financial statements and, hence, in the guidelines.

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”.

 
1
Export