CSA Handbook

CSA Handbook 2024
Corporate Sustainability Assessment

Contents
Introduction ..................................................................................................................................................................5
What is the purpose of this document? ........................................................................................................................... 5
How should you use this document? ............................................................................................................................... 5
General Guidance .............................................................................................................................................................. 6
Media & Stakeholder Analysis.......................................................................................................................................... 7
Assessment focus ............................................................................................................................................................. 8
Company Information ....................................................................................................................................................9

Denominator Revenues .................................................................................................................................................. 9
Economic Dimension ................................................................................................................................................... 10

Transparency & Reporting .............................................................................................................................................. 10
Sustainability Reporting Boundaries ................................................................................................................... 10
Sustainability Reporting Assurance ..................................................................................................................... 12
Sustainability Taxonomies .................................................................................................................................... 14
Corporate Governance .................................................................................................................................................... 17
Board Independence.............................................................................................................................................. 17
Board Type .............................................................................................................................................................. 20
Non-Executive Chairperson/Lead Director .......................................................................................................... 22
Board Diversity Policy ............................................................................................................................................ 24
Board Gender Diversity .......................................................................................................................................... 26
Board Effectiveness ............................................................................................................................................... 28
Board Average Tenure............................................................................................................................................ 30
Board Industry Experience .................................................................................................................................... 32
CEO Compensation Success Metrics ................................................................................................................ 34
CEO Compensation Long-Term Performance Alignment................................................................................. 36
Management Ownership ....................................................................................................................................... 38
Management Ownership Requirements .............................................................................................................. 40
Government Ownership ......................................................................................................................................... 42
Family Ownership .................................................................................................................................................. 44
CEO-to-Employee Pay Ratio.................................................................................................................................. 46
Materiality ........................................................................................................................................................................ 48
Materiality Analysis ............................................................................................................................................... 48
Material Issues for Enterprise Value Creation ..................................................................................................... 51
Materiality Metrics for Enterprise Value Creation ............................................................................................... 53
Material Issues for External Stakeholders........................................................................................................... 55
Materiality Metrics for External Stakeholders .................................................................................................... 58
Risk & Crisis Management .............................................................................................................................................. 62
Risk Governance .................................................................................................................................................... 62
Risk Management Processes ................................................................................................................................ 64
Emerging Risks....................................................................................................................................................... 67
Business Ethics ............................................................................................................................................................... 69
UN Global Compact Membership ......................................................................................................................... 69
Codes of Conduct ................................................................................................................................................... 70
Corruption & Bribery .............................................................................................................................................. 71
Code of Conduct: Systems/Procedures ............................................................................................................... 73
Reporting on Breaches .......................................................................................................................................... 75
Policy Influence ............................................................................................................................................................... 77
Contributions & Other Spending ........................................................................................................................... 77
Largest Contributions & Expenditures ................................................................................................................. 80
Lobbying and Trade Associations - Climate Alignment....................................................................................... 83
Supply Chain Management............................................................................................................................................. 85
Supplier Code of Conduct ...................................................................................................................................... 85
Supplier ESG Programs ......................................................................................................................................... 88
Supplier Screening................................................................................................................................................. 90
Supplier Assessment and Development .............................................................................................................. 93
KPIs for Supplier Screening .................................................................................................................................. 96
KPIs for Supplier Assessment and/or Development ........................................................................................... 98
Tax Strategy ................................................................................................................................................................... 102
Tax Strategy and Governance ............................................................................................................................. 102
Tax Reporting ....................................................................................................................................................... 104
Effective Tax rate ................................................................................................................................................. 106
Information Security/Cybersecurity & System Availability ........................................................................................ 112
IT Security/Cybersecurity Governance ............................................................................................................... 112
IT Security/ Cybersecurity Measures.................................................................................................................. 115
IT Security/ Cybersecurity Process & Infrastructure ......................................................................................... 117
Environmental Dimension ......................................................................................................................................... 120

Environmental Policy & Management.......................................................................................................................... 120
Environmental Policy ........................................................................................................................................... 120
Coverage of Environmental Management Policy ............................................................................................... 122
Verification of Environmental Programs ............................................................................................................ 123
Energy............................................................................................................................................................................. 125
Energy Management Programs .......................................................................................................................... 125
Energy Consumption............................................................................................................................................ 127
Waste & Pollutants ........................................................................................................................................................ 131
Waste Management Programs ........................................................................................................................... 131
Waste Disposal ..................................................................................................................................................... 133
Water .............................................................................................................................................................................. 136
Water Efficiency Management Programs .......................................................................................................... 136
Water Consumption ............................................................................................................................................. 138
Climate Strategy ............................................................................................................................................................ 141
Direct Greenhouse Gas Emissions (Scope 1) ..................................................................................................... 141
Indirect Greenhouse Gas Emissions (Scope 2) .................................................................................................. 145
Indirect Greenhouse Gas Emissions (Scope 3) .................................................................................................. 148
Climate Governance............................................................................................................................................. 152
TCFD Disclosure ................................................................................................................................................... 154
Climate-Related Management Incentives ......................................................................................................... 156
Climate Risk Management .................................................................................................................................. 158
Financial Risks of Climate Change ..................................................................................................................... 161
Financial Opportunities Arising from Climate Change ...................................................................................... 163
Climate-Related Scenario Analysis .................................................................................................................... 165
Physical Climate Risk Adaptation ....................................................................................................................... 168
Emissions Reduction Targets ............................................................................................................................. 170
Net-Zero Commitment ........................................................................................................................................ 173
Biodiversity .................................................................................................................................................................... 175
Biodiversity Risk Assessment ............................................................................................................................. 175
Biodiversity Commitment .................................................................................................................................... 178
No Deforestation Commitment ........................................................................................................................... 182
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Social Dimension ....................................................................................................................................................... 184
Labor Practices .............................................................................................................................................................. 184
Discrimination & Harassment............................................................................................................................. 184
Workforce Breakdown: Gender ........................................................................................................................... 186
Workforce Breakdown: Race/ Ethnicity & Nationality ...................................................................................... 189
Gender Pay Indicators ......................................................................................................................................... 192
Freedom of Association ....................................................................................................................................... 195
Human Rights ................................................................................................................................................................ 196
Human Rights Commitment ................................................................................................................................ 196
Human Rights Due Diligence Process ................................................................................................................ 198
Human Rights Assessment ................................................................................................................................. 200
Human Rights Mitigation & Remediation........................................................................................................... 202
Human Capital Management ....................................................................................................................................... 204
Training & Development Inputs........................................................................................................................... 204
Employee Development Programs...................................................................................................................... 206
Human Capital Return on Investment ................................................................................................................ 208
Hiring 210
Type of Performance Appraisal ........................................................................................................................... 212
Long-Term Incentives for Employees ................................................................................................................. 214
Employee Support Programs .............................................................................................................................. 216
Employee Turnover Rate ..................................................................................................................................... 218
Trend of Employee Wellbeing .............................................................................................................................. 220
Customer Relations ....................................................................................................................................................... 223
Customer Satisfaction Measurement ................................................................................................................ 223
Occupational Health & Safety ...................................................................................................................................... 225
OHS Policy ............................................................................................................................................................ 225
OHS Programs ...................................................................................................................................................... 227
Fatalities ............................................................................................................................................................... 228
Lost-Time Injury Frequency Rate (LTIFR) Employees .................................................................................... 230
Lost-Time Injury Frequency Rate (LTIFR) Contractors ................................................................................... 233
Privacy Protection ......................................................................................................................................................... 236
Privacy Policy: Systems/ Procedures ................................................................................................................. 236
Customer Privacy Information ............................................................................................................................ 239
GRI Mapping Index.................................................................................................................................................. 241

GRI Mapping - Economic Dimension ............................................................................................................................ 241
GRI Mapping - Environmental Dimension ................................................................................................................... 244
GRI Mapping - Social Dimension .................................................................................................................................. 249
S&P Global Sustainable1 Disclaimer ............................................................................................................................ 252
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01
Introduction
What is the purpose of this document?
We believe it is vital that we are transparent about our final section of this document to view the complete table.
Corporate Sustainability Assessment (CSA) process, the Please note we do not guarantee the accuracy of all
methodology and rationale behind the questions we ask, our references to GRI Standards, nor can we guarantee that all
expectations in terms of information and data, and how the references in this document reflect ongoing changes to the
information you provide is used to calculate the S&P Global GRI Standards framework.
CSA Score, a key component of the S&P Global ESG Score.
It is important to note that this document provides
To this end, this document provides companies filling in our supplementary guidance on how to answer the questions; it
CSA questionnaire with information on the general questions should not be used on its own to fill out the questionnaire. For
we ask of companies in all (or many) industries. Our aim is to presentation purposes, there may be some discrepancies
clarify not just the rationale and intent, but also to between this document and the online CSA questionnaire,
provide extra details on the structure of our questions, the and the questionnaire visible via the portal should always be
definitions we use, and guidance on what types of answers considered the master document in terms of the Question
are expected and acceptable for each question. We intend to Layout, and data or information requested. This document
update this document over time to reflect changes to the CSA should be used as a complement to the online questionnaire
and to cover more cross-industry questions (questions and is in no way intended to replace it.
applicable to a majority but not all industries). We are also
sharing the approach by which responses are assessed, what The CSA Handbook serves as an additional source of
information for companies participating in the CSA and for
those that wish to understand the approach to completing the
We provide an overview of links between the CSA and the GRI questionnaire. The CSA Handbook simply serves as additional
(Global Reporting Initiative) Standards at the end of this information the illustrative examples do not serve as
document to help reduce the effort companies need to put in guarantees for a higher S&P Global CSA Score.
to fill in the questionnaire by better understanding where
common metrics or definitions are used. Please refer to the
How should you use this document?

For each covered question, this document provides the The Question Layout sections contain key information about
assessment focus, the question rationale, details of the structure but do not include standard
question layout and specific guidance on how to answer. responses such as Not known
are options for all questions.
The question-specific guidance & definitions sections define
the terms we use and provide details on how to interpret and • The radio button item in the Question Layout sections
of this document indicate that a single answer can be
alignment with the GRI or other standards and framework, selected. A single answer may be followed by a number
and whether internal or public documents will be necessary of multiple-choice items.
to answer the question, in full or in part. • The checkbox item in the Question Layout sections of
this document indicates that multiple answers can be
selected.
online content found in the public domain. This information IMPORTANT NOTE:
must be available to all stakeholders and valid at the time of
the review of the CSA by us. It has to be accessible via a The CSA applies 62 industry specific questionnaires. Up to
weblink (URL). Weblinks on your own website have to be 50% of the CSA questions in an industry questionnaire apply
linked to/from a page on your website that is publicly only to a cross section of industries or are sometimes even
accessible. specific to that single industry. These questions are likely not
covered in this document.
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Whether a question that is contained in this document applies
As of 2021 we provide two CSA versions: a Full CSA containing to your company is determined by your Industry and the
on average 100 questions per industry and a applicable CSA (Full or Core). The full set of criteria and
Core CSA, targeted at medium-size companies, that covers on
average 70 questions. questionnaire section of the CSA portal.
General Guidance
Criterion Weights Answering Questions

The Corporate Sustainability Assessment (CSA) is a holistic This section provides general guidance on how to complete
assessment, but the structure and weighting of each criterion the Corporate Sustainability Assessment, our expectations
depends on its financial materiality in a given industry. To aid and some general tips for a successful submission. Each
companie question in the questionnaire consists of one or more sub-
the different aspects of the assessment on our website under questions. You are given the possibility of selecting one or
CSA Methodology. These weight schemes are also clearly more answers to each question. Generally, the first option will
visible on the Company Benchmarking Scorecard which are enable you to answer the relevant question or sub-questions.
received by all companies following the release of the scores. Each question also contains a standard set of answer options
that enable you to indicate if you do not have the information
asked for or if the question is not applicable to you.
The standard answer options provided in each question are the following:
Answer Option Explanation
No, we do not. Should be used if the company does not have the requested information, policy or strategy.
Not applicable. Please

provide explanations marked as such will be carefully reviewed and only accepted if the question is deemed irrelevant for
in the comment box. fic business model. If a question is marked as not applicable, the weight of the
question will be redistributed amongst the remaining questions in the criterion.
Not known. This answer should be marked if the company is unaware of whether or not the required information is
available within their company or not.
Supporting Evidence
Supporting evidence is asked for in certain questions. If
where either public or non-public references can be provided,
required, supporting evidence is used to verify the submitted
we prefer publicly available documents, as this demonstrates
answers. To support our analysts, please provide the pdf page
more transparency than information that is only internally
available. All questions have a paperclip evidence icon
to make sure that the references provided are considered by
regardless of whether the question explicitly requires
us as you intended, we suggest limiting the number of
supporting evidence. We have long required supporting
references you provide, and that you focus on providing
evidence for a majority of the questions in the CSA and have
references that are clearly relevant for the answers that
been increasing the number of questions for which not only
request one. If you would like to add references for questions
private, but also public references are needed. Growing
that do not require one, you may do so.
scrutiny on the analytical process behind ESG scores requires
enhanced auditing of the answers provided in the CSA: all
References can be either public or non-public, depending on
questions, or, as applicable, single data points, include the
the question. Where publicly available references are
option to attach supporting evidence.
required, this is clearly stated, and the reference can be
added by providing a URL.
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Comments be the exception and not the rule. For example, it can be used
to explain underlying data collection methodologies, changes
The comment box found at the bottom of each question is a
in approaches from one year to another, what parts of the
tool that can be used to provide additional information or
company the data or answers refer to, or why a question is
explanations for the answers that you have provided,
not applicable t
however, the provision of these explanatory comments should
Media & Stakeholder Analysis

We perform a Media & Stakeholder Analysis (MSA) as part of On a daily basis, RepRisk screens, captures, filters and
our assessment methodology to check the consistency of a analyses environmental, social and governance (ESG) risks
behaviour and management of crisis situations in related to companies in 16 languages from a wide range of
line with its stated principles and policies. The MSA is based external stakeholders and third parties.
on an analysis of ongoing company-specific controversies
related to sustainability topics. Results of the MSA range In the event that an MSA case is identified, companies will be
from no impact to high impact, with the latter reflecting contacted with a request for additional information
serious reputational risks that could have consequences for surrounding the case in question. We offer all assessed
the comp companies the possibility to provide us with their feedback on
probability of imminent legal liabilities). In addition, the the ongoing case, the impact on their business and their
reaction to the situation.
response to a situation is assessed, evaluating whether or not
a company has transparently and proactively managed the For more information on the MSA process, please refer to our
issue. Measuring Sustainability Performance white paper
available at our website MSA Methodology
The MSA process is complemented by an additional Guidebook
examination of media coverage, stakeholder commentaries,
and other publicly available sources which are provided by
RepRisk ESG Business Intelligence.
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Assessment focus
In the spirit of transparency, we are sharing the assessment focus of the questions contained in the Handbook. In each question, we
will include icons to give an indication of what we are looking for.
Assessment Focus Icons Description of Information Sought
Disclosure/Transparency Disclosure of qualitative/quantitative information
Documents
Public Documents
Exposure/Coverage Coverage of measures implemented or data reported
Trend Trend of key indicators in the last three or four years
Performance Performance of key indicators in comparison to our expected threshold
Awareness Awareness of internal and external issues and measures taken
External Verification Third party verification of data or processes
PLEASE NOTE: The question texts, methodology, and We also reserve the right to update the contents of the CSA
assessment schemes presented may be subject to change at Handbook and if such updates should take place, there will
any time at the discretion of S&P Global. In addition, be an update of the date shown on the title page of the CSA
questions might look different in the Online Assessment Tool Handbook.
in terms of Question Layout.
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02
Company Information
Denominator Revenues
Question-Specific Guidance & Definitions consistent over four years as well as consistent with
the figures (e.g. Pollutants) provided in the other
The information asked in this question is required by us to
questions.
normalize quantitative data provided in other questions and
• Reporting currency: currency selected will be used
criteria (e.g. Pollutants). Company data reported here may
throughout the questionnaire for consistency
also be used to normalize other reported data in the
purposes, and will automatically be selected for
questionnaire or may be used by us for research purposes.
questions asking for monetary data.
• Unless otherwise specified, all monetary values
• Revenues: Please provide the revenues in your
should be reported in their absolute values.
reporting currency, and indicate which currency you
• If available for your industry, please select the
have used in the comment box. Please provide constant
appropriate normalization factor to be used for
currency (foreign exchange adjusted) revenues if
normalizing data reported in the "Emissions"
possible, as they eliminate the effect of fluctuations in
foreign exchange rates and are thus a better indicator
of business performance. However, reported revenues Supporting evidence:
are also accepted
No document is required to support your response. You may
still provide a reference using the reference clip. This could
• Revenues in US Dollars: Please convert the revenues
include examples of the underlying calculations or
reported in each year using the exchange rate at the
approaches to data aggregation used to compile the provided
end of that corresponding fiscal year. In other words, if
quantitative information.
your company has a fiscal year that ends on the 31st of
December, the revenues provided for FY2019 should be
converted using the exchange rate on 31.12.2019. The Standards & frameworks
revenues provided for FY2020 should be converted
CSRD - S1-6 50a AR 57, S1-6 50c AR 59, S1-6 50d i. AR 60
using the exchange rate on 31.12.2020.
GISD - Revenue and/or (net) value added
GRI Disclosure - 2-7, 201-1
• Total Employees: the number of people employed on a
IRIS+ - FP6510, OD5990, OI3160, OI8864, OI8869, PI1775
full time and part-time basis by the company,
SASB - EM-MM-000.B, RT-AE-000.B, RT-CP-000.C, RT-EE-
calculated as: Total Employees = Full Time Employees
000.B, RT-IG-000.B, SV-PS-000.A, TR-AF-000.C, TR-CL-
+ 0.5 * Part Time Employees. If you calculate your total
000.B, TR-RA-000.E, TR-RO-000.B
number of employees differently, please describe your
WEF Metrics - Economic contribution
method in the comment box.
Data Requirements
• Please provide information for all parts of this
question and ensure that the figures provided are
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03
Economic Dimension
Transparency & Reporting
To confidently use sustainability-related data and reports whether they certify the quality and accuracy of the disclosed
produced by companies, stakeholders must be able to rely on data through third-party verification and assurance
accurate information that has been collected, elaborated and processes, and whether they define the eligibility and/or
presented in a transparent manner. This criterion aims to alignment of their business activities to relevant sustainable
assess how companies set and communicate the reporting finance taxonomies.
boundaries associated to their sustainability-disclosure,
Sustainability Reporting Boundaries
Public: this question requires publicly available information
Assessment Focus
Question Rationale
Setting clear sustainability reporting boundaries is necessary more accurate picture of the environmental and social
for stakeholders and investors to understand how the impacts of the company. Because of this, stakeholders and
sustainability disclosure of a company reflects its established standards and frameworks are expecting
organizational and management reality. The greater the scope companies to increasingly align their sustainability disclosure
of the information is disclosed, the more it is representative with the boundaries set for financial disclosure.
Question Layout
Does your company publicly report on the scope or reporting boundaries of your sustainability disclosure?
□ Yes, we publicly disclose the reporting boundaries or scope of reporting used for our sustainability disclosure. Please
choose the option that best describes your reporting boundaries and provide public supporting evidence:
□ All activities fully consolidated for financial reporting purposes are covered
□ The following percentage of our revenues is covered by our sustainability disclosure:
▪ 75-100%
▪ 50-75%
▪ 25-50%
▪ 0-25%
□ All activities under operational control and/ or majority-owned are covered
□ None of the above applies, but we provide the criteria used for sustainability data disclosure (e.g. list of included or
excluded entities, geographies or divisions)
□ We don't have a dedicated section of our disclosure that describes our reporting boundaries, but we disclose the coverage
of some specific environmental or social indicators. Please select the options that apply:
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□ Some environmental indicators have coverage details
□ Some social indicators have coverage details
Question-Specific Guidance & Definitions section, please consider that a high (75-100%)
revenue coverage
Financially consolidated activities: refer to all subordinate
disclosure or an alignment between the financial
entities, subsidiaries, etc. that the company has consolidated
consolidation and sustainability disclosure are
in its financial statement. Financial accounting standards
considered best practices and should be used as
require reporting companies to consolidate all entities that
options.
they control.
• If the majority of your revenue is derived from
minority (non-consolidated) interests, please use
Operational control: an organization has operational control
the revenue field to indicate the coverage of your
over an operation if the former has the authority to introduce
sustainability disclosure. Please also provide a brief
and implement its processes and operating policies.
description of your minority interests in the
comment box of the question, explaining how they
Majority-owned activities: subordinate entities or
have been included in your sustainability disclosure
subsidiaries in which the reporting company (e.g. parent
and within the CSA.
company) owns more than 50% of outstanding shares.
• If you have used the revenue field, but the revenue
coverage is not explicitly stated in the reporting
Disclosure Requirements: boundaries section of your sustainability
disclosure, please provide the necessary public
• This question requires supporting evidence from the
documents to corroborate the coverage range
public domain. The information provided has to be
provided and indicate the necessary calculations in
included in your public reporting (e.g. annual report,
the comment box. For groups and holding
sustainability report, integrated report, company
companies, this percentage coverage must be
publications, corporate citizenship/corporate social
calculated against the total revenue reported in the
responsibility report, financial report) or corporate
consolidated financial statement.
website.
• Please ensure that the information needed to mark
any of the options is clearly disclosed in the Standards & Frameworks
attached documents
AASB ASRS 1 - 20
CSRD - ESRS 2 BP-1 3, ESRS 2 BP-1 5a, ESRS 2 BP-1 5b i,
Specific requirements for the single-choice selection:
ESRS 2 BP-1 5b ii
• If your company has disclosed the reporting
GRI Disclosure - 2-2
boundaries or scope of reporting used for your
IRIS+ - OI4732
sustainability disclosure, and more than one option
can be selected among those in the single-choice
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Sustainability Reporting Assurance
Assessment Focus
Question Rationale
As with financial data, assurance of environmental and social
data ensures that it is more reliable and increases the trust in published information.
likelihood that investors will use these data in their analysis The purpose of this question is to assess the extent to which
and investment decisions. Transparency about the assurance companies are disclosing the details related to their
environmental and social assurance.
Question Layout
Does the company employ external assurance providers to conduct assurance for its sustainability reporting and is this information
available publicly?
□ Yes, the company's sustainability reporting is externally assured. Please indicate where this information is available in
public reporting or corporate website.
□ The assurance statement is based on a recognized international or national standard (e.g. AAIOOOAS, ISAE 3000).
□ The assurance statement contains a "declaration of independence" which specifies that the assurance provider has no
conflict of interest in relation to providing the assurance of environmental and / social data for the company which has
been assured
□ The scope of the assurance statement clearly indicates that it covers environmental KPIs. If only some KPIs are
assured, then it is clearly indicated which data/KPIs disclosed in the report have been assured.
□ The scope of the assurance statement clearly indicates that it covers social KPIs. If only some KPIs are assured, then it
is clearly indicated which data/KPIs disclosed in the report have been assured.
□
Question-Specific Guidance & Definitions Examples include:
Assurance specialists: Include accountants, certification

• Standard DR03422 (Australia/New Zealand)
bodies, and specialist consultancies. It does not include an
• Assurance Engagements of Sustainability Reports
independent advisory board, stakeholder panel, or high-level
(Germany)
individual (e.g. Environmental Minister).
• Environmental Report Assurance Services
Guidelines by the JICPA (Japan)
The declaration of independence: An explicit statement of
• FAR auditing standard RevR6 (Sweden)
independence from the auditor confirming that there is no
• Standard 3810 Assurance Engagements related to
Sustainability Reports (the Netherlands)
business that could result in a conflict of interest.
• AT-C Section 105 and 210 (United States/Canada)
Recognized international or national standard: refers to

Scope of assurance: If the scope of assurance covers some
assurance standards and not reporting standards (such as
(but not all) environmental indicators, these need to be
GRI guidelines). Examples of these assurance standards are
clearly marked in the relevant sections of the report. If the
AA1000AS and ISAE 3000, but regional or local standards are
assurance statement covers all data items in the report, this
also acceptable if they are clearly specified and are
also needs to be explicitly stated.
comparable to international standards.
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Conclusion/Level of assurance: This refers to the conclusion public reporting (e.g. annual report, sustainability report,
of the assurance process which is according to the level of integrated report, company publications, separate fuel
assurance i.e. limited/moderate or reasonable assurance. The efficiency strategy document) or corporate website.
level of assurance indicates the extent and depth of the work
the assurance provider undertakes in relation to Any response that cannot be verified in the attached public
sustainability disclosures. Most assurance providers offer document(s) will not be accepted.
Standards & frameworks

(i.e. moderate) (GRI, 2013).
CSRD - ESRS 2 BP-2 AR 2
Supporting evidence:
UNGC Questionnaire - G13
This question requires supporting evidence from the public
domain. The information provided has to be included in your
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Sustainability Taxonomies
Assessment Focus
Question Rationale are a range of other jurisdictions that are either developing or
implemented a taxonomy for the classification of green
The purpose of this question is to identify companies that
activities. These may be legally or voluntarily applied.
have business activities that can be considered eligible for or
aligned to a designated sustainable finance taxonomy. In
The S&P Global Inc. Corporate Sustainability Assessment
recent years, there has been a development of sustainable
(CSA) aims to be standard agnostic and therefore the
finance taxonomies which aim to categorize business
question allows participants to designate the taxonomy they
have mapped their operations. It recognizes that companies
Taxonomy, is now legally in force within the European Union;
may do this as they are legally obligated, or they have
in the years to 2025, an increasing number of European
voluntarily mapped their operations to obtain a competitive
companies will be within the scope of this legislation. There
advantage or attract investment.
Question Layout
Does your company report its revenues, capital expenditure and operating expenditure in line with a sustainable activity reporting
framework? Please indicate where this information is available in your public reporting or corporate website.
□ Yes, we have mapped our activities against a sustainability taxonomy or framework, and it is available in company reporting:
Geography of Framework
□ Our company is within the legal scope of a sustainability taxonomy framework within the following geography:
□ European Union
□ China
□ ASEAN
□ South Africa
□ Colombia
□ Japan
□ Korea
□ Other taxonomy, please specify below:
□ Our company is not within the scope of a sustainability taxonomy but we have voluntarily mapped alignment, please specify
below:
Aggregate Mapping
□ Yes, we have conducted an overall aggregate mapping of our eligibility and alignment to the above taxonomy, please
submit details below:
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Aggregate of Eligibility & Revenue Capital Expenditure Operational Expenditure
Alignment
Total figures for your company 100.0% 100.0% 100.0%
Please provide totals in
monetary units
Total of which is Taxonomy-
Eligible
Please provide percentage of
the total figure for your
company that is taxonomy
eligible or meets requirements
of the taxonomy chosen above.
Total of which is Taxonomy-
Aligned
Please provide the percentage
of the eligible figure that is
taxonomy aligned or meets
requirements of the taxonomy
chosen above.
Total of which is not Taxonomy
Eligible
Please review the calculated
totals that are not taxonomy
eligible
□ No, we have not conducted an overall aggregate mapping of our eligibility and alignment to the above taxonomy.
Activity-Level Breakdown of Mapping
□ Yes, we have publicly mapped our eligibility and alignment at activity-level and it is available here:
□ No, we have not publicly mapped our eligibility and alignment at an activity-level.
Activity-Level Mapping: A breakdown of individual activities
Question-Specific Guidance & Definitions and their eligibility as well as alignment to the relevant
sustainability taxonomy.
Sustainability Taxonomy: A framework that provides clear
definitions of business activities that can be considered
Data Requirements:
environmentally or socially beneficial. The framework may be
legally enforced by relevant financial regulators within the Geography of Framework: Please indicate the geography,
jurisdiction in which the company operates, or a voluntary economy, or trading bloc of which your company falls within
framework the company has decided to disclose towards. the scope of its sustainable finance taxonomy. If the company
disclosed towards a taxonomy not within the list, please
Taxonomy-Eligible: A business activity that a sustainability
taxonomy considers relevant to its framework. company voluntarily aligns to a taxonomy that it is not legal
within the scope of, pleas
Taxonomy-Aligned: A business activity that is taxonomy- the scope of a sustainability taxonomy but we have
eligible and passes relevant tests provided by the framework. voluntarily mapped alignment, please specify below
An example within the EU Taxonomy is an eligible Substantial
Contributions, Do No Significant Harm (DNSH), and Minimum Non-EU Companies Guidance: Please note, the list is
Social Safeguards (MSS) to become an aligned activity. forward-looking and although your jurisdiction may be
present, it does not mean your company is required to report
Aggregate Mapping: A total of all the taxonomy-eligible and against it unless legally obligated or voluntarily chosen to. If
taxonomy-aligned activities combined. you are not legally required and have not reported against it,
please choose Not Applicable . Non-EU companies can also
map their data to the EU taxonomy,
15 / 252
is not within the legal scope of a sustainability taxonomy but
Supporting Evidence: The question is public and requires
ng to other evidence to be identified within the company reporting or
taxonomy, write or chose it and submit the percentage of your website.
business meeting those requirements as both eligible and
alignment. For instance, if 90% of your revenues meet the
References
local taxonomy, write 90% in both eligible and alignment.
OECD (2020) Developing Sustainable Finance Definitions and
Aggregate mapping: For company revenue, capital Taxonomies
expenditure, and operating expenses, please provide the OECD (2023) Annex A. Overview of transition finance
following information within the green boxes: approaches | OECD Guidance on Transition Finance : Ensuring
Credibility of Corporate Climate Transition Plans | OECD
Total figures: Totals within the designated currency unit iLibrary (oecd-ilibrary.org)
Center for Clean Air Policy (2022) Towards a common pathway
Total of which is taxonomy-eligible: Total percentage of across sustainable finance taxonomies: Policy brief for
activities that are eligible to the relevant taxonomy. This can decision-makers
EU Taxonomy Compass (2023) Sustainable Finance Taxonomy
expenditure or operational expenditure that is dedicated to South Africa Sustainable Finance Initiative (2023) South
that activity. Africa Sustainable Finance Initiative
Green Taxonomy of Columbia (2023) Columbia Taxonomy
Total of which is taxonomy-aligned: Percentage of total China Green Bond Endorsed Project Catalogue (2015) 中国金
figures that are aligned to the relevant taxonomy. Please 融学会绿色金融专业委员会 (greenfinance.org.cn)
note, this is percentage of total revenue, capital expenditure Association of South-East Asian Nations (ASEAN) (2021)
or operating expenses, not the percentage of the eligible ASEAN Sustainable Finance Taxonomy
figures. Please note that the aligned percentage-value cannot Japan (2021) Basic Guidelines on Climate Transition Finance
be higher than the eligible percentage-value for each item
(revenue, capital expenditure or operating expenses). Standards & frameworks
There is a series of calculated data points that will return CSRD - E1-3 29(c)a, b AR 20, ESRS 2 MDR-A
figures depending on what the participant company submits. EU Taxonomy - Multiple Activities - Disclosures by Non-
Financial Undertakings
Activity-level breakdown: If the company has performed an GISD - Net investment
activity-level breakdown of eligibility and alignment to the SASB - EM-EP-530a.1, EM-RM-530a.1, EM-SV-530a.1, RT-
relevant taxonomy, please indicate where this is in company CH-530a.1
reporting.
16 / 252
Corporate Governance
Corporate governance systems ensure that a company is 2007). On the other hand management incentives have to be
managed in the interests of shareholders (including minority set in such a way that management interests are aligned with
shareholders). On the one hand this includes checks and shareholders' interests. Our questions focus on board
balances that enable the Board of Directors to have structure, composition of the board and related committees,
appropriate control and oversight responsibilities. Empirical board effectiveness and measures to ensure alignment with
evidence suggests that over a period of 5 years, the difference shareholders' long-term interests, which include
in return on equity between well-governed and badly- transparency and the structure of executive remuneration as
governed companies can be as much as 56% (source: GMI well as share ownership requirements.
Board Independence
Flexible: Public information requirements depend on if the company is listed or non-listed.
Assessment Focus
Question Rationale
times, they can also bring specific expertise from their
of directors that is brought in from outside the organization. experience as well as provide additional accountability. We
Independent directors can bring new insights and balance assess the extent to which companies have made explicit
that improve the performance of a company through their statements about their definitions of and requirements with
respect to board members' independence.
Question Layout
Does your company have a publicly available independence statement for the board of directors?
□ Yes, we have a publicly available independence statement. Please indicate below what the statement includes and provide
a reference:
Listed companies are required to provide links to public reports or corporate websites.
Non-Listed companies are required to provide internal documents and/or links to public reports or corporate websites.
□ We comply with the following corporate governance code or stock exchange rules
□ The stock exchange we follow is not on the list or we have our own stricter independence requirements. The requirements
cover the following:
□ The director must not have been employed by the company in an executive capacity within the last year.
□ y parent or
4200 Definitions, including i) payments arising solely from investments in the company's securities; or ii) payments
under non-discretionary charitable contribution matching programs. Payments that do not meet these two criteria are
disallowed.
□
subsidiary of the co
□ The director must not be (and must not be affiliated with a company that is) an adviser or consultant to the company or
□ The director must not be affiliated with a significant customer or supplier of the company.
□
management.
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□ The director must not be affiliated with a not-for-profit entity that receives significant contributions from the company.
□
□ The director must not have any other conflict of interest that the board itself determines to mean they cannot be
considered independent
Target Share
□ We have a target share of independent directors on the board. Please specify:
independence used (i.e., if it is in line with local or

Question-Specific Guidance & Definitions
international standards corresponding to the
Independent directors: are non-executive directors that are definition used by us), and public reporting on the
independent by meeting at least 4 of the 9 criteria (of which at target share of independent directors on the board.
least 2 of the 3 first criteria) listed below: • Please select the stock exchange that you comply
with. We do allow you to select an established
1. The director must not have been employed by the national or stock exchange Corporate Governance
company in an executive capacity within the last Code as long as this also meets our definition of
year. independence.
2. Th • If you are a member of a stock exchange that is not
Member who accepts any payments from the listed or you have stricter requirements, please
company or any parent or subsidiary of the company select what parts of the Board Independence
statement your company satisfies. We expect the
other than those permitted by SEC Rule 4200 statement to meet at least 4 out of 9 criteria of
Definitions, including i) payments arising solely which at least 2 of the first 3. If this is not the case,
from investments in the company's securities; or ii) please indicate so.
payments under non-discretionary charitable
contribution matching programs. Payments that do Specific data requirements for non-listed companies:
not meet these two criteria are disallowed. Family-owned companies
3. mber of an • All family members who are on the Board of
individual who is [...] employed by the company or Directors and employed by the company are to be
by any parent or subsidiary of the company as an considered as executive directors.
• Family members that are only on the board and
4. The director must not be (and must not be affiliated that do not have any executive role can be
with a company that is) an adviser or consultant to considered as independent directors if they meet
the company or a mem at least 4 out of 9 criteria of which at least 2 of the
management. first 3 criteria for independence.
5. The director must not be affiliated with a significant
customer or supplier of the company. State-owned companies
6. The director must have no personal services • Government representatives can be considered as
contract(s) with the company or a member of the they meet at least 4 out of 9
criteria of which at least 2 of the first 3 criteria for
7. The director must not be affiliated with a not-for- independence.
profit entity that receives significant contributions
from the company.
Disclosure Requirements:
8. The director must not have been a partner or
Listed and/or publicly owned companies are required to
the past year. provide links to public reports or corporate websites.
9. The director must not have any other conflict of Non-listed companies are required to provide the following
interest that the board itself determines to not be evidence, depending on the type of company:
considered independent. • Family-owned companies and Privately owned
companies are required to provide public reports,
corporate websites, or internal documents.
Data Requirements:
• Cooperatives are required to provide public reports,
• Please provide your publicly available independence corporate websites, or internal documents.
statement, public reporting on the definition of
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• State-owned companies are required to report on Standards & frameworks
their corporate governance in the public domain as
their key stakeholder is the general public.
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Board Type
Assessment Focus
Question Rationale
An effective board of directors, properly constituted, is the
linchpin of good corporate governance. Boards are focus on its composition, its proportion of independent
responsible for managerial performance, meeting the members, and its overall size, as empirical studies show that
corporation's stated objectives, complying with applicable oversized boards are counter-productive to performance.
laws and regulations, and protecting shareholder rights and
Question Layout
Does your company publicly report on its board type? Please indicate the number of executive and non-executive directors on the
board of directors/supervisory board of your company and specify where this information is available. Additional clarification on one-
tier and two-tier systems is available in the information text.
□ Yes, we publicly report on our board type.

Please select whether your company has a one-tier or two-tier board and provide a reference:
□ One-tier system (companies with a board of directors)
Number of members
Executive directors
Independent directors
Other non-executive directors
Total board size
□ Two-tier system (companies with a supervisory board)
Number of members
Supervisory board Independent directors
Other non-executive directors
Employee representatives
(if not applicable, please leave the field empty)
Management board/executive Senior executives
management
Total size of both boards
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Types of Boards: Companies can choose between one- and • Ensure that the type of board, the breakdown between
two-tier systems when answering the question. The the different types of directors, and the total board size
descriptions below will help you identify which of these are filled out.
structures your company has in place. • If the definition of independence at the company
differs from our definition given in the Board
One-tier systems: have a single board consisting of executive, Independence question, please adjust the number of
non-executive, and independent directors. It is possible that independent directors in line with our definition and
such boards only consist of independent directors or a provide a comment in the comment box.
combination of executive and independent directors. Most
countries use a one-tier system. Specific data requirements for non-listed companies:
Family-owned companies
Two-tier systems: have an executive board and a supervisory • All family members who are on the Board of
board, which is composed of non-executive or independent Directors and employed by the company are to be
members and in certain countries employee considered as executive directors.
representatives. Countries that commonly use two-tier • Family members that are only on the board and
systems include Austria, Denmark, Finland, France, Germany, that do not have any executive role can be
Hungary, and The Netherlands. Sweden and Norway are considered as independent directors if they meet
exceptions and should be classified as one-tier despite the at least 4 out of 9 criteria of which at least 2 of the
presence of employee representatives on the board. first 3 criteria for independence.
For French companies that have a one-tier board system with State-owned companies
employee representatives, in accordance with the French • Government representatives can be considered as
code of corporate governance, employee representatives they meet at least 4 out of 9
should be considered non-executive directors and be criteria of which at least 2 of the first 3 criteria for
included in the total board size. independence.
Types of Directors: We outline definitions of possible types of

directors below. These definitions should be used to classify
board members. Please note we only consider board Listed and/or publicly owned companies are required to
members that are CURRENTLY (at the time the assessment is provide links to public reports or corporate websites
performed) on the board, e.g., if a board member has resigned
(for example in March 2020) and the assessment is performed Non-listed companies are required to provide the following
in May 2020, that board member would not be considered. evidence, depending on the type of company:
• Family-owned companies and Privately owned
Executive directors: are employees, and are usually senior companies are required to provide public reports,
managers of the company in an executive function (e.g., CEO, corporate websites, or internal documents.
CFO, etc.). • Cooperatives are required to provide public reports,
Independent directors: are non-executive directors that are • State-owned companies are required to report on
independent by meeting the requirements set out in the their corporate governance in the public domain as
Board Independence question. their key stakeholder is the general public.
Other non-executive directors: are directors that are not Standards & frameworks
executives but also do not qualify as independent as defined
above. They are members of the board not already accounted CSRD - ESRS 2 GOV-1 21a, ESRS 2 GOV-1 21b, ESRS 2 GOV-1
for in the executive and independent categories. They might 21e
be employed by the organization at a non-executive level. EDCI - Total number of board members
IRIS+ - OI1075, OI4070
Data Requirements: UNGC Questionnaire - G11
WEF Metrics - Governance body composition
This question is automatically filled out with information from
S&P Capital IQ. If any correction is required, please follow
these requirements:
21 / 252
Non-Executive Chairperson/Lead Director
Assessment Focus
necessary checks and balances to avoid potential abuse of

Question Rationale
power. Companies headed by a joint chairperson/CEO are
International consensus favors the separation of the roles of expected to explain their reasoning for this structure, have
chairperson and CEO. If the board of directors opts to appoint appointed a "lead independent director" and should provide a
one person fulfilling both roles, it has to build in the statement about the lead d
Question Layout
Is the board of directors/supervisory board headed by a non-executive and independent chairperson and/or an independent lead
director? Please indicate where this information is available.
□ Chairperson is non-executive and independent.

□ Role of CEO and chairperson is split and former CEO/chairperson (presently in a non-executive position) is now
chairperson
□ Role of CEO and chairperson is split and chairperson is non-executive but not independent
□ Role of CEO and chairperson is split and former CEO/chairperson is now chairperson, but independent lead director is
appointed. Please indicate the name of the lead director:
□ Role of chairperson and CEO is joint, but independent lead director is appointed. Please indicate the name of the lead
director:
□ Role of chairperson and CEO is joint or chairperson is an executive director.
Question-Specific Guidance & Definitions in excess of $60,000 during the curr

other than those permitted by SEC Rule 4200
Independent lead director: this role exists to provide
Definitions, including i) payments arising solely
leadership to the board in cases where the joint roles of
from investments in the company's securities; or ii)
Chairperson and CEO could potentially be in conflict.
payments under non-discretionary charitable
Fundamentally, the role exists to ensure that the board
contribution matching programs. Payments that do
operates independently of management and that directors
not meet these two criteria are disallowed.
have independent leadership at the board level. If the
3.
company has chosen either of the two options indicating that
individual who is [...] employed by the company or
it has an independent lead director, the name of this director
by any parent or subsidiary of the company as an
should be provided in the comment box.
4. The director must not be (and must not be affiliated

Independent directors: are non-executive directors that are
with a company that is) an adviser or consultant to
independent by meeting at least 4 of the 9 criteria listed (of
which at least 2 of the first 3 criteria) listed below:
management.
5. The director must not be affiliated with a significant
1. The director must not have been employed by the
customer or supplier of the company.
company in an executive capacity within the last
6. The director must have no personal services
year.
contract(s) with the company or a member of the
2.
Member who accepts any payments from the
company or any parent or subsidiary of the company
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7. The director must not be affiliated with a not-for- Non-listed companies are required to provide the following
profit entity that receives significant contributions evidence, depending on the type of company:
from the company. • Family-owned companies and Privately owned
8. The director must not have been a partner or companies are required to provide public reports,
employee corporate websites, or internal documents.
the past year. • Cooperatives are required to provide public reports,
9. The director must not have any other conflict of corporate websites, or internal documents.
interest that the board itself determines to mean • State-owned companies are required to report on
they cannot be considered independent. their corporate governance in the public domain as
ESG Disclosure Standards (China) - G.1.2.1 Composition and
provide links to public reports or corporate websites
background of board members
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Board Diversity Policy
Assessment Focus
Question Rationale Diversity adds value to the board through differences in

perspectives and experience. Diverse boards will be able to
assess problems from a broader point of view and are more
likely to take into account the best interests of all
shareholders and other stakeholders. Boards are the direct
stakeholders. Furthermore, studies have shown a positive
representatives of these stakeholders and form one of the
correlation between gender diversity on boards and
most important components of corporate governance. It is
therefore important that the board members selected have
for board members to have a broad and complementary range
the right experience and skills, are sufficiently independent,
and act in the best interests of all stakeholders.
companies and industries depending on the existing and
required skills of board members and the pool of qualified
board members available when electing new board members.
Question Layout
Does the company have a formal policy on board diversity and is it available publicly?
□ Yes, the company has a policy on board diversity that clearly requires diversity factors such as gender, race, ethnicity, country
of origin, nationality or cultural background in the board nomination process. Please indicate where this information is
available in public reporting or corporate website.
 Gender
 Race or Ethnicity
 Nationality, country of origin or cultural background
Question-Specific Guidance & Definitions response are considered for the board nomination
process.
Local corporate governance codes: Certain local corporate
governance codes include guidance on diversity criteria. This
Race: In the absence of any internationally agreed definition,
can be accepted in this question if both of the following
race is most often statistically characterized in terms of
criteria apply:
phenotype and appearance (e.g., skin colors), or with regard
to ancestry. This should not be understood as an attempt to
• The company states that it adheres to the local
trace the definition of race to biological, anthropological, or
corporate governance code without exception OR
genetic factors but rather to (somewhat artificially)
clearly states what those exceptions are and that
distinguish it from the concept of ethnicity. (OECD, 2018)
they do not include the diversity factors specifically
ticked in the question, and
Ethnicity: Describes a shared culture: the practices, values,
• The local corporate governance code clearly
and beliefs that characterize those belonging to a community.
indicates that the specific criteria ticked in the
This multidimensional concept acts as an umbrella term
24 / 252
encompassing language, religious traditions, and others Disclosure Requirements
(United Nations, 2017). A number of related concepts,
including ancestry, citizenship, and nationality, may overlap
provide links to public reports or corporate websites
with ethnicity. However, ethnicity is not the same as
nationality or citizenship, nor it is a measure of biology or
Non-listed companies are required to provide the following
genes. (OECD, 2018)
evidence, depending on the type of company:
Nationality: While geographic diversity has received less
attention than gender or racial diversity on boards, it is clear
that geographic diversity adjusts the lens through which risks
• Cooperatives are required to provide public
and strategies are examined. In order to manage global risks
reports, corporate websites, or internal documents.
and opportunities and improve board effectiveness,
• State-owned companies are required to report on
geographic diversity in the boardroom in a global marketplace
needs to increase. Here, nationality captures a person's
country of origin or citizenship

Data Requirements:
CSRD - ESRS 2 MDR-P 65a
A board diversity policy needs to contain specific
requirements for diversity factors being taken into account
IRIS+ - OI0667, OI4221, OI9485
during the board nomination process. Statements related to
non-discrimination between sexes, nationalities, etc. or
statements confirming that a company complies with local
laws around non-discrimination are not sufficient.
For two-tier board structures, the policy needs to apply to the

supervisory board, not only the management board.
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Board Gender Diversity
Assessment Focus
Question Rationale
We assess whether the board reflects the diversity of the which in turn benefits long-term shareholder value. Gender
workforce and marketplace, thereby ensuring that a variety of diversity has been an important topic of discussion in recent
viewpoints are heard and factored into corporate decision- years, and various academic studies have shown a correlation
making. A commitment to diversity at all levels can help between gender diversity and corporate performance, for
companies attract employees, create goodwill with example, in corporate governance (Adams and Ferreira, 2009)
consumers, and better compete in diverse markets globally, or company innovation (Deszö and Ross, 2012).
Question Layout
Please indicate the number of women on your company's board of directors/supervisory board and specify where this information is
available. If your company has a one-tier board structure, this figure includes: female executive directors, non-executive directors
and independent directors. If your company has a two-tier board structure, this figure ONLY includes female independent directors
and non-executive directors (this means that senior executives and employee representatives should not be included).
□ Number of female directors:
senior executives and employee representatives should not

be included). Hence, the management board should not be
Data Requirements considered in this question.
For two-tier boards: Employee representatives and senior

executives should not be included in the total number of
women for two-tier boards as they are not considered in the
calculation of the total size of the supervisory board. Listed and/or publicly owned companies are required to
provide links to public reports or corporate websites.
For one-tier boards: Employee representatives should not be
included in the total number of women on the board for one- Non-listed companies are required to provide the following
tier boards. If there are no women on the board of directors or evidence, depending on the type of company:
supervisory board, please write 0 in the answer to this • Family-owned companies and Privately owned
question. companies are required to provide public reports,
For this question, we are looking for the number of women on • Cooperatives are required to provide public
your company's board of directors/supervisory board. reports, corporate websites, or internal documents.
• If your company has a one-tier board structure, this their corporate governance in the public domain as
figure includes female executive directors, non- their key stakeholder is the general public.
executive directors and independent directors.
• If your company has a two-tier board structure, this
References
figure ONLY includes female independent directors
and non-executive directors (meaning
26 / 252
found a significant positive relationship between the fraction GISD - Number of female board members, Percentage of
of women or minorities on the board and firm value. female board members
IRIS+ - OI8118
SFDR Principal Adverse Impacts - Board gender diversity
CSRD - ESRS 2 GOV-1 21d UNGC Questionnaire - G11
EDCI - Number of women board members WEF Metrics - Governance body composition
ESG Disclosure Standards (China) - G.1.2.1 Composition and
background of board members
27 / 252
Board Effectiveness
Assessment Focus
Question Rationale
An effective board of directors is vital for good corporate information on how board members are elected. The
governance. Several studies have found that companies with frequency of elections and structure of the process can affect
specific procedures and practices designed to ensure the the accountability of board members: when board members
accountability of their board and a close alignment with are elected individually and on an annual basis, shareholders
perform better than those that do not. are able to vote them off if they are concerned with their
We use the parameters in this question as a proxy for the performance. If shareholders can frequently express their
overall effectiveness of the board. In addition to meeting confidence in or concerns about board members, the board as
attendance, the number of external directorships board a whole becomes more accountable.
members hold, and performance assessment, we ask for
Question Layout
How does your company ensure the effectiveness of your board of directors/supervisory board and the alignment with the (long-term)
interests of shareholders?
Indicators/measures
Board Meeting Attendance  Average board meeting attendance:
Number of meetings attended in percentage last ___% of meetings of board of directors/supervisory board
business/fiscal year.  Minimum of attendance for all members required, at least
(in %)
Board Mandates  Number of non-executive/independent directors with 4 or
Number of other mandates of the board of less other mandates:
directors/supervisory board members. This only applies to ___ please provide the names of these directors
non-executive and independent directors, not executive  Number of other mandates for non-executive/independent
directors or employee representatives. directors restricted to:
Board Performance Review  Regular self-assessment of board performance.
Performance assessment of board of directors/supervisory Please specify or provide documents:
board members.  Regular independent assessment of board performance.
Please specify or provide supporting documents:
Board Election Process  Board members are elected and re-elected on an annual
basis.
 Board members are elected individually (as opposed to
elected by slate).

This question only applies to board members who represent should only include the supervisory board and not the
shareholders (or multiple stakeholders including management board.
shareholders). For two-tier board structures, this question
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Meeting attendance: this section refers to two measures: on is elected on an individual basis (as opposed to members
one hand, the actual average attendance rate for the past being elected by slate).
year, and on the other hand, if there is any corporate guideline
for meeting attendance, i.e., if there is a minimum proportion
of board meetings that each board member is required to
attend. Both rates should be calculated on the basis of the Listed and/or publicly owned companies are required to
total number of board meetings held annually. provide links to public reports or corporate websites
Other mandates: refers to the number of other external Non-listed companies are required to provide the following
directorships in publicly listed companies held by members of evidence, depending on the type of company:
the board of directors/supervisory board (examples include • Family-owned companies and Privately owned
executive board positions such as CEO, or member of the companies are required to provide public reports,
board of directors at another company). Board memberships corporate websites, or internal documents.
in private limited companies, educational institutes (schools, • Cooperatives are required to provide public
colleges, or universities), and non-profit organizations are not reports, corporate websites, or internal documents.
considered in our definition of other mandates. Only the • State-owned companies are required to report on
number of mandates for independent and non-executive their corporate governance in the public domain as
directors should be considered, not mandates for executive their key stakeholder is the general public.
directors or employee representatives. In this section, the
actual number of directors with four or fewer other mandates References
is considered together with any corporate guidelines on
restrictions on the number of other mandates. Corporate Accountability Report "Does Corporate Governance
Matter t
Board Performance Assessments: We consider two types of S. Leving, ISSN 1542-9563
assessments: (1) self-assessments

performance, meaning that the board members themselves McKinsey Strategy & Corporate Finance "Toward a Value-
are allowed to systematically evaluate their performance; (2) Creating Board" by Conor Kehoe, Frithjof Lund, and Nina
independent assessments Spielmann
meaning that an independent third party evaluates the

board ce. Such assessments are considered Standards & frameworks
regular if the company clearly shows that there are
ESG Disclosure Standards (China) - G.1.2.2 Board of Directors
guidelines to perform them at specific intervals (such as
operating procedures and conditions
annually or every second year). Assessments are also
GISD - Attendance rate of board meetings
considered regular if the company is carrying them out for the
GRI Disclosure - 2-10, 2-18, 2-9
first time but with the explicit intention of conducting them
IRIS+ - OI3630
regularly. It is considered best practice to carry out both
WEF Metrics - Governance body composition
types of assessments on a regular basis, although not
necessarily annually.
Annual election of board members: refers to a procedure

whereby each board member has to be re-elected at each
annual general meeting for shareholders (as opposed to
electing a member for multiple years). Individual election of
board members refers to a procedure whereby each member
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Board Average Tenure
Assessment Focus
Question Rationale
reflects retention and continuity on one hand, and
refreshment of skills and perspectives, and independence on
shareholders and other stakeholders. Boards are the direct the other.
representatives of these stakeholders and form one of the
most important components of corporate governance. It is Research strongly supports the assertion that optimal board
therefore important that the board members selected have tenure is in the 7 to 12-year range, and that firm value
the right experience and skills, are sufficiently independent, declines as average tenure deviates therefrom.
and act in the best interests of all stakeholders. Board tenure
Question Layout
company has a one-tier board structure, this figure includes all members (executive directors, non-executive directors and
independent directors). If your company has a two-tier board structure, this figure ONLY includes independent directors and non-
executive directors (e.g. exclude employee representatives). Please indicate where this information is available.
□ Average tenure of board members in years:
Data Requirements
For two-tier boards: Employee representatives and senior
In this question, we expect disclosure on average board
executives should not be included in the calculation for two-
tenure and/or individual tenure of each member of the board
tier boards, as they are not considered in the calculation of
of directors.
the total size of the supervisory board. The management
board members should not be included when calculating the
Tenure: the number of years a member has served on the
average tenure.
board of directors. Please consider the calendar year as the
base year. For example: if a director was appointed in March
For one-tier boards: All board members should be reported,
2014, their tenure would be counted as 2022-2014 = 8 years.
including executive, independent and non-executive
members.
Mergers and Acquisitions: If the company is a spin-off or
merger, tenure from the previous company is counted.
If a company is less than 10 years old, the company should

mark the question as Not Applicable.
30 / 252
Disclosure requirements:
Listed and/or publicly owned companies are required to References
Sterling Huang. Board Tenure and Firm Performance. INSEAD
Business School. May 2013.
Canavan, et al. Board tenure: How long is too long? Directors &
Boards. 2004.
corporate websites, or internal documents. Standards & frameworks
• Cooperatives are required to provide public ESG Disclosure Standards (China) - G.1.2.1 Composition and
reports, corporate websites, or internal documents. background of board members
• State-owned companies are required to report on GRI Disclosure - 2-9
their corporate governance in the public domain as WEF Metrics - Governance body composition
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Board Industry Experience
Assessment Focus
Question Rationale
the right experience and skills, are sufficiently independent,
and act in the best interests of all stakeholders. This question
shareholders and other stakeholders. Boards are the direct focuses on industry and audit experience, two of the most
representatives of these stakeholders and form one of the important skill sets for setting strategies and effectively
most important components of corporate governance. It is monitoring and evaluating management's performance.
therefore important that the board members selected have
Question Layout
Please indicate the number of board members with relevant work experience in your company's sector according to GICS Level 1
Number of independent or non-executive members with industry experience (e.g. excludes executives):
Please list the independent or non-executive directors included in the above count:
Executives and Employee Representatives: Board members

Question Specific Guidance & Definitions
who are executives or elected as employee representatives
Board Industry Experience: The member must have practical are not included.
work experience in the industry (based on GICS 1
classification below). This experience can be acquired either Data Requirements
by way of functions in management, academia, consulting, or
In this question, we expect disclosure on the number of
research. 'Practical work experience' in the industry refers to
independent or non-executive members of the board of
experience attained in employee or executive roles. Having
directors with industry experience and/or disclosure on the
been on another company's board in the same industry does
industry experience of each individual board member.
not qualify as relevant experience.
Two-tier board structures: this question should only include

GICS Level 1 sectors:
the supervisory board and not the management board.
• Energy
• Materials Disclosure Requirements
• Industrials
• Consumer Discretionary Listed and/or publicly owned companies are required to
• Consumer Staples provide links to public reports or corporate websites.
• Healthcare
• Financials Non-listed companies are required to provide the following
• Information Technology evidence, depending on the type of company:
• Communication Services • Family-owned companies and Privately owned
• Utilities companies are required to provide public reports,
• Real Estate corporate websites, or internal documents.
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their corporate governance in the public domain as CSRD ESRS 2 GOV-1 21c AR 5
their key stakeholder is the general public. GRI Disclosure - 2-9
For companies in the FBN, TCD and IDD industries: if your

company has very diversified operations or significant
investments into businesses in industries other than the one
used for the purpose of this assessment, board experience
from another relevant industry can be accepted if an
explanation is provided, clearly indicating the other GICS
sector and how it relates to the company.
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CEO Compensation Success Metrics
Assessment Focus
Question Rationale
The use of financial metrics to evaluate management including the use of return metrics (capital efficiency) and
performance has become ubiquitous as the benefits of relative metrics which compare the company to peers. In this
aligning incentives with company performance have been question, we aim to find out which corporate performance
established. Our research shows that the use of revenue, indicators are used to determine CEO variable compensation.
operating profit, and EPS are common practices. Please include only metrics applied to the CEO.
Differentiation is now only observed in a few aspects,
Question Layout
Does the company have predefined corporate performance indicators relevant for the Chief Executive Officer's variable compensation
and is it available publicly?
Non-Listed companies are required to provide internal documents and/or links to public reports or corporate website.
□ Yes, th
compensation. Please indicate where this information is available in public reporting or corporate website.
 Financial Returns (e.g. return on assets, return on equity, return on invested capital, etc.). Please list all metrics used for
this category:
 .
Please list all metrics used for this category:
Question-Specific Guidance & Definitions metrics include Return on Assets, Return on Equity, Return on
Invested Capital.
Success metrics for variable CEO compensation: As part of
this question, any corporate performance indicator that is
used to determine the CEO's variable compensation should be Data Requirements
indicated. Please only include metrics that apply to the CEO's
Please only include metrics that apply to the CEO's
compensation, not metrics that are selectively used for other
compensation, not metrics that are selectively used for other
senior executives or specialist senior managers at a lower
senior executives or specialist senior managers at a lower
level (such as CFO or COO).
level (such as CFO or COO).
Financial metrics: Financial Returns refer to capital

efficiency (capital is the source of funds, debt, equity, etc.). Disclosure Requirements:
Therefore, Financial Returns always use an Income Statement Listed and/or publicly owned companies are required to
profit metric (e.g., EBIT, income, operating income) divided by provide links to public reports or corporate websites.
a Balance Sheet metric (e.g., Assets (entire balance sheet),
Equity, Total Capital (debt plus equity), Invested Capital. We Non-listed companies are required to provide the following
do not accept revenue growth, net profit after taxes, earnings evidence, depending on the type of company:
per share, and dividends per share. Acceptable financial
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• Family-owned companies and Privately owned Standards & frameworks
WEF Metrics - Remuneration
35 / 252
CEO Compensation Long-Term Performance Alignment
Assessment Focus
Question Rationale
Both financial and non-financial metrics are becoming several ways, including deferral of short-term compensation,
increasingly important in determining variable compensation time vesting, and long-term performance periods. Alignment
for executive management and more specifically the CEO. In with long-term performance is particularly important during
this question, we assess time vesting and performance periods of short CEO tenure, as the risk of short-termism
increases. For example, in 2009, CEOs of S&P 500 companies
compensation. A longer vesting period ensures that the held their position for an average of just 7.2 yrs. This has
interests of management and the long-term interest of subsequently increased to 10.8 years in 2015 as the economy
shareholders are better aligned. Additionally, we assess if the recovered and turnover declined, but the risk of a reversion
short-term bonus is deferred in shares or stock options. remains. (Matteo Tonello, The Conference Board, Inc., 2016).
A longer vesting period ensures that the interests of
The economic alignment of management with the long-term management and the long-term interest of shareholders are
performance of the company is an essential component of better aligned.
executive compensation. This alignment can be achieved in
Question Layout
Does your company have the following compensation structures in place to align with long-term performance? Please indicate where
this information is available:
□ Yes, our company has guidelines on deferred bonus, time vesting, and performance period for the
Deferral of Bonus for Short-term CEO Compensation

short-term incentive deferred in the form shares or stock options?
Please indicate the percentage of the short-term bonus deferred in in the form of shares or stock options:
Performance Period for Variable CEO Compensation
What is the longest performance period applied to evaluate variable compensation (based on predefined targets, either relative or
absolute), covered in your executive compensation plan? Is there a clawback policy in place? Please note that compensation that only
is time vested is not considered as performance-based compensation in this part of the question.
Please indicate the longest performance period covered by your executive compensation plan:
 We have a clawback provision in place. Please specify:
Time Vesting for Variable CEO Compensation
Please indicate the longest time vesting period for variable CEO compensation:

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Deferred shares: refer to the percentage of the short-term Exceptions to the Standard Methodology for Non-Listed
bonus paid out in deferred shares instead of cash. The companies:
company can choose to pay out the annual short-term bonus The definition of shares includes non-tradable stock and
in deferred shares to the CEO and other executive directors
which is seen as a best practice. practice performance.
Deferred bonus compensation is an arrangement in which a Phantom / synthetic shares: A phantom stock is an employee
portion of an employee's income is paid out at a later date benefit plan that gives selected employees (senior
after which the income was earned during a set performance management) many of the benefits of stock ownership
period. without actually giving them any company stock. This is
sometimes referred to as shadow stock. Phantom stock, also
Performance period: This refers to a performance-based pay- known as synthetic equity, has no inherent requirements or
out structure of variable compensation for the current period restrictions regarding its use, allowing the organization to use
x which is dependent on achieving targets in the following is however it chooses.
periods (x+1, x+2, x+3, etc.). Please note that option- and
stock-based compensation for which the number of options
Data Requirements
or stocks rewarded is not dependent on future performance
do not count as performance vesting but are considered as In this question, we assess the time vesting and performance
time vesting. periods as well as whether the company has a clawback
provision in place. In addition, we asses if the short-term
bonus is deferred in shares or stock options.
earned and payable under the awards will generally range
from 0% to 200% of the target number of units based on The question applies to CEO compensation only.
achievement of the specified goals over a two-year period."
A clawback provision: a policy that allows a company to
recover performance-based compensation for some period of Listed and/or publicly owned companies are required to
time after compensation awards are granted. Clawback provide links to public reports or corporate websites.
provisions may apply to short and/or long-term awards. The

circumstances and conduct that would trigger clawback Non-listed companies are required to provide the following
provisions include, but are not limited to, restatement of evidence, depending on the type of company:
financial results, errors in financial information reported, • Family-owned companies and Privately owned
misconduct by the employee directly, or misconduct by any companies are required to provide public reports,
other employee that results in incorrect financial reporting. corporate websites, or internal documents.
Time vesting: refers to time-based pay-out structures of reports, corporate websites, or internal documents.
variable compensation for the current period x over the • State-owned companies are required to report on
coming years (x+1, x+2, x+3, etc.). The amount of future their corporate governance in the public domain as
payout is independent of the coming year's performance. If all their key stakeholder is the general public.
long-term incentives are based on future performance, the

same figure should be given for the longest performance Standards & frameworks
period and the longest time vesting period.
SASB - FN-IB-550b.1, FN-IB-550b.2
We accept the total number: the sum of the vesting period
and the required holding period.
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Management Ownership
Partially public: additional credit will be granted for relevant publicly available evidence.
Assessment Focus
Question Rationale
As corporate governance systems aim to ensure that a research suggests that stock ownership by senior
company is managed in the interests of its shareholders, in management is positively correlated to financial
performance.
other executive officers have stock ownership. Academic
Question Layout
in the calculation should not be hedged or the personal financial risk of holding the shares otherwise removed.
□ Yes, company CEO and other executive officers hold company shares:
Position Name(s) Multiple of base salary

Chief Executive Officer
For Listed companies: The information is publicly available. Please

provide link to public reports or corporate website.
For Non-Listed companies: The information is available in internal
documents, public reports or corporate website.
Average across other executive committee members owning shares
For Listed companies: The information is publicly available. Please

provide link to public reports or corporate website.
For Non-Listed companies: The information is available in internal
documents, public reports or corporate website.
Question-Specific Guidance & Definitions Chief Executive Officer: Base salary and shareholdings of the
Chief Executive Officer or shareholding expressed multiple of
Shares: Shares are units of equity ownership in a corporation.
the CEO base salary.
but also other forms of participation in equity ownership.

Other Executive committee members: Base salary and
shareholdings of at least two members of the executive
Economic interest in shares held: the shares included in the
committee or average shareholdings of the executive
calculation should not be hedged or the personal financial
committee expressed as multiple of base salary. Please note
risk of holding the shares otherwise removed.
that the metrics need to be reported for each named
executive individually (a consolidated figure is not sufficient).
Data Requirements
The question assesses the stock ownership level of the Additional credit will be granted for public reporting of the
CEO and of the other member of the executive committee following parts of the question:
compared to their respective base salary.
• CEO's shares as a multiple of base salary
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• Average across other executive committee number of shares held by the executive 2 / base salary of
members owning shares as a multiple of base salary
reported
Disclosure requirements for partially public question:
For US-based companies, please use the share price at the
For Listed companies, if no public documentation is provided, time of the shareholder meeting, and the salary and number
internal documentation should be provided that includes the of shares held at that time for the purpose of calculations.
base salary and shareholdings reported as well as the
calculations.
References
Academic research (e.g. Bhagat and Bolton 2008) shows that
For non-listed companies, internal documents are generally
stock ownership of senior management is positively related to
accepted. future operating profit.
Other research includes:

Calculations:
• Core & Larcker (2000). Performances consequences of
CEO multiple calculation: Share price at the end of the FY *
mandatory increases in executive stock ownership.
number of shares held by the CEO / base salary of CEO
• Gugler, Mueller, & Yurtoglu (2008). The Effects of
Ownership Concentration and Identity on Investment
Other executives' multiple calculation: (share price at the end
Performance: An International Comparison
of the FY * number of shares held by the executive 1 / base
salary of executive) + (share price at the end of the FY *
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Management Ownership Requirements
Assessment Focus
Question Rationale
As corporate governance systems aim to ensure that a executives. Academic research (e.g. Bhagat and Bolton 2008)
company is managed in the interests of its shareholders, in suggests that stock ownership by senior management is
this question we assess whether there are stock ownership positively correlated to future operating profit.
Question Layout
Does your company have specific stock ownership requirements for the CEO and other members of your executive committee? Please
indicate where this information is available:
□ Yes, there are specific requirements in place. Please indicate at which levels this exist and indicate the share ownership
requirements as a multiple of the annual base salary.
 The CEO has to build up a share ownership of ______ times the annual base salary.
 Other members of the executive committee besides the CEO have to build up a share ownership of ______ times the annual
base salary.
Data Requirements
Exceptions to the Standard Methodology for Non-Listed
The question assesses if there are explicit requirements companies:
indicating that the CEO and/or other executive managers are
The definition of shares includes non-tradable stock and
required to build up share ownership equivalent to a specific
multiple of their annual base salary.
practice performance.
Disclosure requirements: Phantom / synthetic shares: A phantom stock is an employee
Listed and/or publicly owned companies are required to benefit plan that gives selected employees (senior
provide links to public reports or corporate websites. management) many of the benefits of stock ownership
without actually giving them any company stock. This is
Non-listed companies are required to provide the following sometimes referred to as shadow stock. Phantom stock, also
evidence, depending on the type of company: known as synthetic equity, has no inherent requirements or
• Family-owned companies and Privately owned restrictions regarding its use, allowing the organization to use
companies are required to provide public reports, is however it chooses.

References
• State-owned companies are required to report on Academic research (e.g., Bhagat and Bolton 2008) shows that
their corporate governance in the public domain as stock ownership of senior management is positively related to
their key stakeholder is the general public. future operating profit.Others:
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• Core & Larcker (2000), Performances consequences of Standards & frameworks
mandatory increases in executive stock ownership.
IRIS+ - OI5660
• Gugler, Mueller, & Yurtoglu (2008), The Effects of
Ownership Concentration and Identity on Investment
Performance: An International Comparison
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Government Ownership
Assessment Focus
Question Rationale
As corporate governance systems aim to ensure that a Academic research (e.g., Goldeng et. al., 2008 or Chen et. al.,
company is managed in the interests of its shareholders, in 2017) suggests that companies without government
this question we assess if a government has voting rights of ownership perform better than companies with government
more than 5% and has golden shares in the company. ownership.
Question Layout
Please indicate whether individual governmental institutions own more than 5% of the total voting rights of your company and if yes,
whether golden shares exist for them. Government ownership of 5% or less of the voting rights need not be reported. Please also
indicate where this information is available. For additional information, please see the information button.
□ Yes, individual governmental institutions have more than 5% of the voting rights.
Please provide the total percentage of government ownership (sum of % of individual governmental institutions owning more than 5%
of voting rights):
Please provide details for the government ownership (e.g., calculation, members, organizations, etc. if available):
Golden Shares for Governmental Institutions

Does your company have golden shares for governmental institutions?
□ Yes, our company has golden shares for governmental institutions.

□
o No governmental institutions own more than 5% of the total voting rights. Please provide available evidence of the company
share ownership structure.
Golden Shares for Governments: A type of share that gives its

shareholder veto power over changes to the company's
Government Ownership: For the definition of government charter. A golden share holds special voting rights, giving its
institutions and ownership, we adopt the Organization for holder the ability to block another shareholder from taking
Economic Co-operation and Development (OECD) definition more than a ratio of ordinary shares.
through full, majority, or significant minority ownership. In

Data Requirements
this definition, we include state-owned enterprises (SOEs)
which are owned by the central or federal government, as well Government ownership requirements:
a Holding companies that own stakes higher than 5% in other

companies, and in turn are majority owned by a government
This definition includes Government pension funds, state or governmental institutions should be reported in this
asset management funds, development banks (federal and question. For example, a holding company (Company A) is
local), and sovereign wealth funds. 70% government owned. Company A owns 40% of the voting
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rights in Company B. Company B should report 40% References
government ownership in this question.
• Goldeng, Grünfeld, & Benito (2008), The
In this question, we expect information on:
Performance Differential between Private and State
• Total percentage of government ownership (sum of
Owned Enterprises: The Roles of Ownership,
% of individual governmental institutions owning
Management and Market Structure.
more than 5% of voting rights) or disclosure of all
• Chen, Ghoul, Guedhami, & Wang (2017), Do state
individual governmental institutions owning more
and foreign ownership affect investment efficiency?
than 5% of voting rights
Evidence from privatizations.
• Golden shares for governmental institutions (only if
the corresponding option is marked).
Disclosure requirements GRI Disclosure 2-15, 201-4

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Family Ownership
Assessment Focus
Question Rationale
As corporate governance systems aim to ensure that a of the voting rights. Academic research (e.g. Eugster & Isakov,
company is managed in the interests of its shareholders, in 2016 or Corstjens, Peyer & Van der Heyden, 2006) suggests
this question we assess if one or several individuals of the that family ownership is positively correlated to future
founding family are ultimate owners and have more than 5% operating profit.
Question Layout
Please indicate whether one or several founding individuals or family members, personally or through other companies or
organizations, individually have more than 5% of the voting rights of your company. Please also indicate where this information is
available. For additional information, please see the information button.
o Yes, founding individuals or family members individually own more than 5% of the voting rights.
Total % of voting rights of the company:
Please provide details for the individual/family ownership (e.g., calculation, members, organizations, etc. if available):
o No, founding individuals or family members individually do not have more than 5% of the voting rights.
Question-Specific Guidance & Definitions Total % of voting rights of founding family members,
personally or through companies/organizations to be
Significant family ownership: At least one of the founding
reported:
individuals/family members, personally or through other
• if one of the family members owns more than 5%, the
companies or organizations, must own more than 5% of the
voting rights of your company. If no individual owns more than
holdings, e.g., add the person(s) with individual
5%, we do not consider it significant family ownership.
ownership of over 5% of the voting rights plus those
who individually own less than 5% of voting rights.
Founding family: The founding family can be one or several
Please report the total even if there is no pooling
individuals or family members. They might have not
agreement in place.
necessarily set up the company independently. In case a
• if the family owns more than 5% of the company
family acquires an existing company and transforms it into a
through a holding company, the family must own at
new company, this second family can be considered the
least 50% of the holding company that in turn holds
'founding family'(e.g., if a company has been acquired, re-
shares of the company.
named, and re-branded).
• if none of the family members individually own more
than 5% of the company's voting rights, please mark
Data Requirements "No, (founding) family members individually do not
We are looking for founding family ownership, in order to have more than 5% of the voting rights."
assess whether descendants of the founding families are • If any of the founding members or their families still
current owners with significant voting rights. hold more than 5%, this should be reported.
• if the company was not founded by a family, please
mark 'Not Applicable'
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Specific data requirements for non-listed companies • State-owned companies are required to report on
• For family-owned companies, the distribution of voting their corporate governance in the public domain as
rights can also be evaluated if there are no publicly their key stakeholder is the general public.
traded shares, as there exist other types of shares/
instruments that correspond to voting rights. References
• Credit Suisse (2017), The CS Family 1000
• Eugster & Isakov (2016), Founding family
ownership, stock market performance and agency
Listed and/or publicly owned companies are required to problems.
provide links to public reports or corporate websites. • Corstjens, Peyer & Van der Heyden (2006),
Performance of Family Firms: Evidence from US and
Non-listed companies are required to provide the following European firms and investors.
corporate websites, or internal documents. GRI Disclosure 2-15
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CEO-to-Employee Pay Ratio
Assessment Focus
Question Rationale
In the aftermath of the global financial crisis, many countries investors and stakeholders whether executive compensation
have implemented or are planning to implement reforms is justified.
regarding the transparency of executive compensation. In this question, we assess whether companies (including
Transparency is vital to restore trust among shareholders, non-US-based companies) are able to disclose this
employees, customers and other stakeholders, and hence to information. The Dodd-Frank Wall Street Reform and
improve corporate reputation. Companies that are taking a Consumer Protection Act (Pub.L. 111-203, H.R. 4173) is a
proactive approach to align their reporting with this global federal statute in the United States that was signed into law
trend and improve disclosure about executive compensation by President Barack Obama on July 21, 2010. The Dodd-Frank
will be in a better position to fend off criticisms than those Act clearly states that, in terms of CEO compensation
that are not. disclosure, a company will be obliged to disclose to the
shareholders: the median of the annual total compensation of
In addition to complying with new regulations, transparent all employees of the issuer, except the chief executive officer
reporting on CEO compensation and the mean or median (or any equivalent position), the annual total compensation of
compensation of other employees provides a basis for the chief executive officer, or any equivalent position, and the
understanding the "pay gap" and addresses concerns from ratio of the amount of the medium of the annual total with the
total CEO compensation.
Question Layout
Please provide the annual compensation for the Chief Executive Officer and the median of the annual compensation of all other
employees as well as the ratio between the two. If you are unable to provide the median, please provide figures for total mean
compensation and the ratio using the mean. The currency provided should remain consistent for all figures.
CEO Compensation Total CEO Compensation

Please indicate the total annual compensation of the Chief Executive Officer (or any
equivalent position):
Total compensation includes fixed and variable compensation as well as all other parts
of compensation which are required to be included in total remuneration reporting
according to national accounting standards
Employee Compensation Median Employee Mean Employee
Compensation Compensation
Please indicate either median or mean annual compensation of all employees, except
the Chief Executive Officer (or any equivalent position):
The ratio between the total annual compensation of the Chief Executive Officer and the
mean or median employee compensation:
CEO compensation divided by the mean or median employee compensation
The currency used in the table:
Public Reporting
Š For Listed companies: The information is publicly available. Please provide link to public reports or corporate website.
For Non-Listed companies: The information is available in internal documents, public reports or corporate website.
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Salary: It is defined here as the total annual compensation
including all bonuses but excluding pension benefits and Disclosure requirements for partially public
fringe benefits. question:
For Listed companies: Additional credit will be granted for
Total annual compensation: It is defined here as the total
relevant publicly available evidence covering one of the
compensation including all bonuses but excluding pension
following aspects of this question:
benefits and fringe benefits
• Annual compensation of Chief Executive Officer and
median (mean) annual compensation of all employees
Median of the total annual compensation of all employees: It
except the Chief Executive Officer (or any equivalent
is defined according to the general mathematical definition of
position)
median: the median of a sequence is the middle number when
• Ratio between the total annual compensation of the
sorting all numbers from low to high. This is different from the
Chief Executive Officer and the median (mean)
mean of the total annual compensation of all employees since
employee compensation
the mean of a sequence of numbers is calculated by adding
up all the numbers in a sequence and dividing this total by the For Non-Listed companies: internal documents covering the
number of entries in the sequence. In this question, either the above mentioned information are generally accepted.
median or the mean may be provided; it is not necessary to
provide both.
References
The ratio should be calculated as the Total CEO The Dodd Frank Wall Street Reform and Consumer Protection
Compensation divided by the Median OR Mean employee Act (Pub.L. 111-203, H.R. 4173),
compensation (i.e., the reported figure should be the multiple www.gpo.gov/fdsys/pkg/BILLS-111hr4173enr/pdf/BILLS-
of the employee compensation). 111hr4173enr.pdf (p. 529)
Data Requirements Standards & frameworks
While we expect the figure to cover the entirety of a CSRD - S1-16 97b AR 101
GISD - Wage level (%)
may make cost-of-living adjustments to the compensation of GRI Disclosure - 2-21
employees residing in a jurisdiction different from that of the IRIS+ - OD3292
CEO, provided that these adjustments are applied to all such SFDR Principal Adverse Impacts - Social and employee
employees included in the calculation, and that these matters
adjustments are explained in the company comment section, WEF Metrics - Wage level (%)
and the raw, unadjusted data is also provided in the company

comment section.
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Materiality
This criterion aims to assess the company's ability to identify A sustainability issue is seen as material if it presents a
sustainability factors that are relevant for long-term value significant impact on society or the environment and might
creation, considering the interrelation between external
impact on society or the environment on the one hand and competitive position, and long-term shareholder value
internal impact on enterprise value on the other hand. It creation. Material ESG issues can significantly affect an
therefore considers the dual nature of materiality, also entity's business operations, cash flows, legal or regulatory
referred to as double materiality. Investors are increasingly liabilities, and access to capital. They can also significantly
interested in both sides of this equation. The same holds for
regulations across the world, who are requiring reporting on with key stakeholders, society and the environment. Over
this broader and integrated understanding of materiality. time external impacts on society and environment translate
into internal impact on a company itself, including its
financial value drivers.
Materiality Analysis
Assessment Focus
Question Rationale
The purpose of this question is to assess the extent to which 4. Integration of materiality assessment in the
companies are disclosing the details related to their compa
materiality process. We are looking for the following evidence 5. Assessment conducted is based on the principle of
in the public domain: double materiality i.e., considers internal impact on
1. Frequency of conducting or reviewing materiality the business as well as external impact on society
analysis and the environment
2. Involvement of external stakeholders in identifying 6. Materiality assessment process is verified by third-
the material issues party assurance provider
3. Prioritization of material issues in a materiality 7. Materiality assessment results are signed off by
matrix or any other form either board of directors or senior management
Question Layout
Does the company disclose details of its materiality determination process and how the materiality analysis is conducted, and is this
information available publicly?
□ Yes, the company has disclosed its materiality analysis process. Please indicate where this information is available in
 Materiality analysis conducted/reviewed:

□ At-least annually
□ Once every 2 or more years
□ Not known
 Involvement of external stakeholders in identifying the material issues
 Material Issues are prioritized in a materiality matrix or any other form
 Materiality assessment integrated in company's ERM process
 Assessment conducted is based on the principle of double materiality i.e., considers internal impact on the
business as well as external impact on society and the environment
 Materiality assessment process verified by a third-party assurance provider
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 Materiality assessment results signed off by:
□ Board of Directors
□ Senior Management

Materiality: Any factor that can have a present or future Not acceptable:
impact on value creation and therefore the financial • Only stating that stakeholders are involved without
performance of the company over time. These could be any reference to the type i.e., external or internal
economic, environmental, or social in nature. stakeholders
• General stakeholder engagement information
Internal Impact: ess operations, without any reference to how it is integrated with
cash flows, legal or regulatory liabilities, and access to the materiality assessment process is not
capital. It can also be perceived as an improvement or acceptable
undermain
with key stakeholders, society, and the environment. 3. Prioritization of material issues:
Our expectations
External Impact: direct and indirect damage or benefits to • Material issues should be publicly disclosed and
prioritized either in a matrix format or any other
business activities, business model, products, and services, priority listed format
both in the short and longer term. Not acceptable:
• Only stating that a materiality
Materiality Assessment: A materiality assessment is an determination/prioritization process has been done
approach to identify critical economic, environmental and without disclosing the top material issues.
social issues which have a significant impact on the
company's business performance. 4. Integration of materiality assessment results in
enterprise risk management (ERM):
Materiality Assessment Frequency: We expect companies to Our expectations:
conduct/ review materiality assessment and to report the • Public disclosure on the integration of materiality
results in at least one of the two most recent Annual or assessment results within the overall risk
Sustainability reports. management process
• Description of how identified material issues are
linked with the company's significant risks
Data requirements
Not acceptable:
Copy of or link to the Company website, annual report, • General disclosure on ESG-related risks without
sustainability report, or other public communication specifying the linkage with materiality assessment
results
1. Materiality analysis conducted/reviewed: • ERM results used as inputs to materiality process
Our expectations
• Public disclosure on the frequency of materiality 5. Assessment conducted is based on the principle of
analysis conducted or reviewed. The information double materiality i.e., considers internal impact on
should be available in at least one of the two most the business as well as external impact on society
recent Annual or Sustainability reports and the environment
Not acceptable: Our expectations:
• Reference to previous public reports for materiality • Indication of considering external and internal
analysis which are more than 2 years old impacts on the materiality assessment in company
public reports/website
2. Involvement of external stakeholders: • A materiality matrix depicting both: the impact of
Our expectations society, the
• Whether external stakeholders are involved in the environment and people and the internal impact on
materiality analysis process should be clearly the business.
available in the Not acceptable:
documents/website. • General disclosure on impact valuation analysis
• Information should be available in the section without reference to its link with identified material
where materiality analysis has been discussed issues
49 / 252
References
6. Materiality assessment process verified by third-
The double-materiality concept Application and Issues - GRI
party assurance provider:
EU Guidelines on non-financial Reporting directive 2.2
Our expectations:
(2019)
• Public disclosure on assurance report clearly
Corporate Sustainability Reporting Directive (CDRD)
specifying audit of materiality assessment covered
Double Materiality Guidelines - EFRAG
in its scope
S&P Global ESG Scores: Materiality Methodology - S&P (link
• A statement specifying external assurance of the
available as of April 2023)
materiality assessment process
The Two Dimensions of ESG Materiality - S&P
Not acceptable:
Statement-of-Intent-to-Work-Together-Towards-
• Disclosure of the involvement of external consultant
Comprehensive-Corporate-Reporting.pdf (sasb.org) CDP,
in materiality assessment process
CDSB, GRI, IIRC and SASB
• Assurance statement without clear indication of
materiality assessment under its scope
Standards & Frameworks
7. Materiality assessment metrics signed off by the
CSRD - ESRS 2 IRO-1 53b iii., ESRS 2 IRO-1 53e, ESRS 2 SBM-
Board of directors or Senior Management:
2 45b AR 16
Our expectations:
Review, sign-off, approved, oversight of materiality
IRIS+ - PD2756
assessment process by:
WEF Metrics - Material issues impacting stakeholders
• the board of directors, a sub-committee of the
board of directors, or a single named director OR
• an executive manager/executive committee
• The materiality assessment results are signed by
the respective board/executive representative(s)/
• A general statement specifying sign-off/approval of
materiality assessment result is also sufficient
Not acceptable:
• Executive manager/sustainability manager involved
in the materiality assessment process
Disclosure Requirements
• The document(s) you attached will be used to verify
your response.
• The supporting documents need to be available in
the public domain.
• Any response that cannot be verified in the attached
public document(s) or web link will not be accepted.
50 / 252
Material Issues for Enterprise Value Creation
Assessment Focus
Question Rationale
Leading companies are increasingly focusing on the most Companies are asked to make a business case and therefore
material topics that drive their long-term value creation. should focus on those economic, environmental, or social
These issues can cover economic, environmental, and social issues that are most important or impactful for the business
issues, and they are key drivers for a company's long-term performance of the company. Companies should indicate
business performance. The question assesses whether which of the three value drivers are impacted by these issues
companies have conducted a materiality analysis of the most (revenues, costs, or risk), and what strategies, products, or
important issues driving long-term value creation and initiatives the company has that are linked to these issues.
whether they are able to convincingly link these issues to
their business performance.
Question Layout
Does the company conduct materiality analysis to identify the three most important material issues (economic, environmental, or
social) that have the greatest impact on the business, report on how these issues impact the business and serve as significant
determinants of long-term value creation, and are these information available publicly?
□ Yes, the company materiality analysis to identify key issues for long-term value creation. Please indicate where this
information is available in public reporting or corporate website.
Material Material Material

Issue 1 Issue 2 Issue 3
Material Risk or Opportunity
Please specify the material risk or opportunity impacting your business:
Business Case
Please provide a brief rationale for why this issue is material to your business:
Business Impact
Please select the type of impact this material issue has on your business (cost/revenue/risk):
Business Strategies
Please specify your primary business strategies, initiatives or products that address this
issue.
Question-Specific Guidance & Definitions social issues which have a significant impact on the
company's business performance.
Material Issue: A material issue is a sustainability factor that
Materiality Assessment Frequency: We expect companies to

drivers, competitive position, and therefore on long-term
conduct a materiality assessment and to report the results in
shareholder value creation.
at least one of the two most recent Annual or Sustainability
reports.
Materiality Assessment: A materiality assessment is an
approach to identify critical economic, environmental, and
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Data Requirements 3. Business Strategies
Our expectations:
1. Material Issue
• The company provides a clear explanation of the
Our expectations:
strategies, initiatives, or products or services
• Companies have conducted a materiality analysis
through which it addresses the material issue.
and identified the most important issues driving
Not acceptable:
long-term performance.
• Strategies, initiatives, or products or services that
• Companies clearly define the three most material
do not directly address the material issue.
economic, environmental or social issues driving
• Strategies that are not clearly described (e.g.,
long-term value creation.
human resources-oriented management).
Not acceptable:
• Description of the current situation without
• Purely financial metrics/issues (net profit, cash
providing the strategies or products to address this
flow, earnings per share, product sales).
situation.
• Operational business metrics/issues (e.g. market
• Provision of a target instead of a strategy, initiative,
expansion, efficient use of capital, operational
or product (e.g., zero fatalities or injuries).
excellence).
• General issues without a description of the specific
sub-issues that might impact the Disclosure Requirements
performance (e.g. macroeconomic conditions, long-
term shareholder value).
your response.
Please note that companies that do not provide an acceptable
the public domain.
material issue do not receive points for any of the sub-
questions related to that material issue.
public document(s) or weblink will not be accepted
2. Business Case
Our expectations: Standards & frameworks
The business case should contain the following information:
CSRD - ESRS 2 BP-2 17a, ESRS 2 BP-2 17c, ESRS 2 BP-2 17d,
• A clear link between the material issue and the
ESRS 2 SBM-3 48b
business case.
• Clear explanation of why the issue is material to the
cost/revenue/risk (e.g., cost savings, revenue

generation, operational risks with direct impact on
financial performance).
Not acceptable:
• The business case is not linked to the material
issue.
• The Business case does not link the material issue
ms of costs,
revenues, or risks.
• The business case is describing the material issue
and its importance for the society/environment but
does not provide information on why the issue is
, impact
of global warming on society).
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Materiality Metrics for Enterprise Value Creation
Assessment focus
Question Rationale
The purpose of this question is to assess the extent to which the top material issues identified over the long term, the
companies are disclosing their progress toward established question asks which targets/metrics the company uses to
targets or metrics linked to material issues. In order to ensure measure its performance over time and whether the company
that the company is managing its performance in relation to has linked its executive compensation to these issues.
Question Layout
Do you have targets or metrics linked to the top three material issues and disclose progress towards these? Do you link executive
compensation with the targets or metrics involved? Please specify where the information is available in public reporting.
□ Yes, we do have targets or metrics linked to the top three material issues and report them publicly
Material Material Material

Issue 1 Issue 2 Issue 3
Material Issue
Please specify your material issue:
(The issues should be same as marked in the question Material Issues)
Target/Metric
Do you have a target or metric to measure your progress on this issue in a systemic way?
Please specify where this target or metric is available in public reporting:
Target Year
Please specify the year for the target:
Progress
Do you disclose the progress on targets/metrics. Please specify where this target or metric is
available in public reporting:
Executive Compensation
Is this metric or target used to determine the compensation of executive committee
member(s)? If yes, please specify how this metric is used and provide a relevant public
reference showing how these metrics are applied to executive compensation.
Data Requirements
1. Material Issues
Our expectations: • The material issues should be the same as
• Companies have conducted a materiality analysis identified in question 1.3.2
and identified the most important issues driving Not acceptable:
long-term performance. • Purely financial metrics/issues (net profit, cash
• Companies clearly define the three most material flow, earnings per share, product sales).
economic, environmental or social issues driving • Operational business metrics/issues (e.g., market
long-term value creation. expansion, efficient use of capital, operational
excellence).
53 / 252
• General issues without a description of the specific
sub- 4. Executive Compensation:
performance (e.g., macroeconomic conditions, long- Our expectations:
term shareholder value). • The metric or target used for determining executive
compensation is clearly defined and linked to the
Please note that companies that do not provide an acceptable material issue. It should also be available publicly.
material issue do not receive points for any of the sub- • Executive compensation is linked to the
questions related to that material issue. performance on the material issue, metric or target
(e.g., as part of an executive scorecard).
2. Target/ Metric: • There is a clear indication that the performance on
Our expectations: the provided material issue, target, or metric is
• The metric or target is linked to the material issue linked to the compensation of the executive
and should be available publicly management, not only of the respective line
• Both long-term ( at-least 3 or more years) or short- managers.
term targets are acceptable Not acceptable:
• The metric or target and how it is being used are • The executive compensation is linked to the
clearly described.
• Target set in the past year is acceptable if: environmental performance.
- • The metric/target is used for determining
ongoing, (such as zero fatalities) please management performance but there is no
indicate the current year as the target year and explanation of how performance is linked to
explain in the company comment section. executive compensation.
- The current reporting year (e.g., 2021) • The metric/target indirectly contributes to the
- If the company publish its report biannually or (e.g., executive compensation is linked to EBIT, as
improved operational eco-efficiency reduces
assessment cycle operational costs and therefore increases EBIT).
Not acceptable: • For additional information, please check our
• Targets/metrics are not linked to the material issue. webcast on this topic.
• Vague targets or targets whose progress cannot be
measured (e.g., ensure a good working environment, Disclosure Requirements
reduce workplace accidents).
• Targets set in the past year and are not valid • The document(s) you attached will be used to verify
anymore your response.

3. Target Year: the public domain.
Our expectations: • Any response that cannot be verified in the attached
• The target year should be available in public domain document(s) or weblink will not be accepted.
Indicating the current reporting year as the target year is

acceptable if: Standards & frameworks
• t is by necessity, ongoing,
CSRD - ESRS 2 BP-2 17b, ESRS 2 GOV-3 29b AR 7, ESRS 2
(such as zero fatalities) please indicate the current
MDR-M 77c, ESRS 2 MDR-T 80e AR 24 - AR 26, ESRS 2 MDR-T
year as the target year and explain in the company
80j AR 24 - AR 26
comment section.
Indicating past reporting years as target year is acceptable if:
WEF Metrics - Progress against strategic milestones,
-
Remuneration
ongoing, (such as zero fatalities) please
indicate the current year as the target year and
explain in the company comment section.
- The current reporting year (e.g., 2021)
- If the company publish its report biannually or
assessment cycle
54 / 252
Material Issues for External Stakeholders
Assessment Focus
Question Rationale
impacts resulting from business operations, products,
The purpose of this question is to recognize companies that services or supply chain operations are significantly under-
identify and value the externalized impact generated on reported. Impact valuation helps companies to increase
societal stakeholder groups and/or the environment as a awareness of externalities associated with their business and
result of their main business activities. The impact evaluated represents a management tool to orient the company strategy
usually relates to environmental and/or social externalities towards sustainable activities, solutions, and sourcing.
that can be either positive (external benefits) or negative Investors are also interested in how companies measure and
(external costs), intended or unintended. The impacts understand their own impacts, and how those companies use
generated can be direct or indirect and are usually not that information in their internal decision-making so that it
internalized as part of the costs associated with the business leads to long-term value creation. Over time, external impact
activity. on society and the environment also translates into internal
impact on a company itself, including its financial value
While companies have made significant progress in tracking drivers. In a broader understanding of enterprise value today,
and reporting input and output measures (such as water use including stakeholder perspectives, the interrelation between
and C02 emissions), the external social and environmental external and internal impact is a core part of determining
materiality.
Question Layout
Has your company conducted a materiality analysis to identify and value the positive/negative impact on external stakeholders
associated with your indicate two material issues
that illustrate the most significant social or, environmental impact on external stakeholder groups (e.g. environment, society,
customers, etc.). Note that philanthropic initiatives or project-based Environmental and Social Impact Assessments (ESIA, EIA) are
not accepted in this question.
□ Yes, our company conducted an assessment of positive and/or negative impacts on external stakeholders resulting from our
business operations, products & services and/or supply chain.
Please provide supporting evidence:
Impact 1 Impact 2
Material Issue for External Stakeholders Please select the category your Please select the category your
Please specify the material issue that external impact belongs to: external impact belongs to:
generates a positive/negative impact on [Dropdown: 25 options] [Dropdown: 25 options]
external stakeholders.
Cause of the Impact Business value chain: Business value chain:
Please specify which part of your business is
responsible for the external impact and the □ Operations □ Operations
coverage of the business activity that has □ Products/Services □ Products/Services
been considered in the assessment. □ Supply chain □ Supply chain
Business activity coverage: Business activity coverage

External stakeholder(s)/ impact area(s) □ Environment □ Environment
evaluated □ Society □ Society
55 / 252
Please select the stakeholder(s) group or □ Consumers/end-users □ Consumers/end-users
impact areas evaluated.
□ External employees (e.g. □ External employees (e.g.
supply chain, contractors) supply chain, contractors)
Topic relevance on external stakeholders □ Materiality of externalized □ Materiality of externalized
Please provide a brief rationale why the impact on stakeholders impact on stakeholders
external impact assessed is material to assessed. assessed.
external societal stakeholders or the
environment. Also indicate the type of impact Type of impact: Type of impact:
assessed along with public disclosure, if o Positive o Positive
available. o Negative o Negative
o Both combined o Both combined
□ Information is publicly □ Information is publicly

available available
stakeholder(s) evaluated, and requires a clear link between

the material issue and the relevance to external stakeholders.
Material issue for external stakeholders: The material The description may also refer to the direct or indirect
significance of an ESG subject in terms of external impact is consequences of the impact generated on societal or
s environmental stakeholders in terms of size, severity, and/or
activities, business model, products, and services. Impacts extent of the damage or benefits caused to societal
are evaluated considering the direct and indirect impacts on stakeholders and the environment. The type of impact
societal stakeholders and/or the environment, both in the assessed can be positive, negative, or both. The two impacts
short and longer term. The material issues for external reported can be both positive or negative but companies are
stakeholders and associated impact are usually identified by encouraged to assess their external impacts in a combined
evaluating the breadth of the impact, looking at the size of the way in order to measure together the positive and negative
effect on societal stakeholders and the environment, as well impacts.
as the depth of the impact, looking at the severity and extent
of the damage or benefits it causes to societal stakeholders
and the environment. Data Requirements
Acceptable forms of reporting (non-exhaustive) on material
Cause of the impact:
issues with externalized impact include
activity in terms of operations, products/services, or supply
chain activities which are responsible for causing the external
• Materiality analysis/metrics with the integration of
impact. The coverage associated with the business activity
external impact aspects.
refers to the share of company operations, products/
• Strategic section of a report or website: Reporting
services, or supply chain considered as part of the impact
on key strategic areas as part of a Sustainability
evaluations.
Report or the website, will only be accepted as long
as there is a clear reference to the external impact
External stakeholders/ impact areas evaluated: This refers to
dimension, meaning a detailed explanation of why
the type of external stakeholder group or an external area
the issue and associated impact assessed is
experiencing the impact caused by the company through its
material to external societal stakeholders or the
business activities. External groups or areas include the
environment.
environment, society, consumers/end-users, and external
• Impact valuation section of a report, website, or a
employees (supply chain, contractors). It is possible to
single specific document.
consider the impact on several areas or groups, e.g.,
environment and society or, environment, consumers and
Not acceptable material issues: Please note that companies
society, etc. As the question is assessing material issues for
that do not provide an acceptable material issue for external
external stakeholders, internal stakeholders, such as
stakeholders will not receive points on any subsequent
employees or shareholders, are not acceptable.
aspects of the question. Not acceptable examples include the
following:
Topic relevance on external stakeholders: This explains why
the external impact assessed is material for the external
56 / 252
• Purely economic or financial issues: Tax payments, References
net income, amortization & depreciation, interests,
Natural Capital Protocol
dividend payments, salaries, own employment,
https://naturalcapitalcoalition.org/protocol/
macroeconomic conditions, etc.
https://naturalcapitalcoalition.org/wp-
• Operational business issues: Market expansion,
content/uploads/2016/07/Framework_Book_2016-07-01-
efficient use of capital, operational excellence, etc.
2.pdf
• Material business issues without providing
Social & Human Capital Protocol
information on why the issue is relevant to external
https://capitalscoalition.org/capitals-approach/social-
stakeholders
human-capital-protocol/
• Impacts from philanthropic activities or project-
Social Value UK
based mandatory environmental and social impact
https://www.socialvalueuk.org/
assessments.
https://www.socialvalueuk.org/resource/discussion-
document-valuation-social-outcomes/
Disclosure requirements for partially public https://www.socialvalueuk.org/app/uploads/2017/11/Discus
question: sion_Paper_on_SVP_NCP-FINAL-VERSION-2-1.pdf
All qualitative information required in this question needs to World Business Council For Sustainable Development
be supported by attached private or public documents(s) or a (WBCSD):
comprehensive company comment. Options that cannot be
https://www.wbcsd.org/Programs/People-and-
verified in supporting documents will be unticked.
Society/Tackling-Inequality/Resources/WBCSD-Measuring-
Additional credit will be granted for relevant publicly
Impact
available evidence covering the following aspect of the
question: https://docs.wbcsd.org/2017/05/IVR_Impact_Valuation_Whit
e_Paper.pdf
• Topic relevance on external stakeholders
Business for Societal Impact B4SI, (formely London
Benchmarking Group LBG):
https://b4si.net/framework/
Social Return on Investment (SROI)
https://www.socialvaluelab.org.uk/wp-
content/uploads/2016/09/SROI-a-guide-to-social-return-on-
investment.pdf
Impact Reporting & Investment Standards (IRIS)
https://iris.thegiin.org/
Impact Management Project
https://impactmanagementproject.com/

CSRD - ESRS 2 GOV-2 26c, ESRS 2 IRO-1 53b ii., ESRS 2 SBM-
3 48a
57 / 252
Materiality Metrics for External Stakeholders
Assessment Focus
Question Rationale external society and/or environment, and also which

valuation technique is used to assess the impacts identified.
The purpose of this question is to assess the extent to which
companies are evaluating the positive and/or negative
Companies can use impact valuation techniques to assess
impacts they are causing on external stakeholders using
and compare the potential impacts that their products,
quantitative metrics linked to the material issues identified in
services, or operations have had (or may have) on people and
the materiality assessment. To ensure that the company is
the environment. Investors can use impact valuation
assessing those impacts, the question asks which
techniques to assess and compare the potential impacts that
quantitative metrics are being used to measure the output of
companies they are financing or considering financing may
its business activity, the impact that activity has on the
have on people and the planet, as well as their own investor
contribution to those impacts.
Question Layout
Have you evaluated the positive/negative impacts on external stakeholders using quantitative output and impact metrics? Please
note that philanthropic initiatives or project-based impact assessments are not accepted in this question.
□ Yes, we have quantitative metrics used to value the external impact caused on society and/or the environment.
Impact 1 Impact 2
Material Issue for External Stakeholders

Please specify the material issue that generates a
positive/negative impact on external stakeholders.
Output Metric □ Quantitative output □ Quantitative output
Please specify the quantitative metric/s used to measure metric/s linked to metric/s linked to
the output of the direct environmental and/or social material issue material issue
results of the business activity.
Impact Valuation □ Impact valuation □ Impact valuation
Please specify whether you have conducted an impact conducted conducted
valuation converting the output metrics to an impact
metric to measure the societal or environmental external Description of the impact Description of the impact
impact. Please choose the quantitative metric used in the assessed assessed
valuation from the list and provide a description of the
impact assessed.
Impact Metric □ Quantitative impact □ Quantitative impact
Please specify the quantitative metric used to measure metric linked to metric linked to
your external impact. material issue material issue
□ Information is □ Information is
publicly available publicly available
58 / 252
Question-Specific Guidance & Definitions - disruption of the rain cycle,
- increase in land temperature,
Output Metric: This refers to the environmental or social
-
direct results caused
• A change in the quality or availability of natural
terms of operations, products/ services and/or supply chain.
resources:
The metrics must be directly linked to the material issue.
- destruction of ecosystems, fauna, and flora,
Performance metrics included in the IRIS (Impact Reporting &
- Decreased/Increased access to natural resources
Investment Standards) catalog are accepted as good practice
- Damage/Improvement to/of heritage, spiritual or
to define output targets to measure social and environmental
cultural resources
success:
- Decreased/Improvement of quality or availability of
Examples of environmental outputs that could be used to set
natural resources
a specific quantitative metric:
• Air pollution reduction (in % or C02 emissions, NOx
Examples of social impacts
Emissions, SOx emissions).
•
• Avoided C02 emission in % or tons, avoided NOx
and interact with one another.
emissions, avoided SOx emissions.
- A change in the community: its cohesion, stability
• Water pollution reduction (% of contaminated
and character.
potable water).
- Capacity and Quality of Infrastructure, services, and
• Ground pollution reduction (in % or tons of waste
disposed to landfill, incinerator).
life and/or health.
• Waste diverted from landfill (in ton or %).
• A change in health status and wellbeing (physical,
• Percentage of energy recovered.
mental, social, and spiritual wellbeing):
- Improved health awareness.
Examples of social outputs that could be used to set a
- Deterioration in health status.
specific quantitative metric:
- Capacity and cost of Local Health Providers.
• Number of entrepreneurs that received a
• A change in personal and property rights, such as
microfinance loan.
violation of their civil liberties.
• Number of fatalities.
• Other changes:
• Number of permanent illnesses.
- Increase/ decrease in local economic development
• Sales of products protected by intellectual property
(note that employment is an output metric).
rights.
- Reduced/increased inequality: distributional impact
e.g., on vulnerable households.
Impact Valuation: This refers to the process of valuing and
- Enhanced local work experience, skills, and
quantifying the external damages and/or benefits (positive/
employability.
negative externalities) to the society and the environment
that are caused as a result of the direct environmental and/ or
To evaluate the external impacts, companies could use
different methodologies or standards that can range from
The valuation usually involves quantitative or monetary
standard methodologies from third parties to the company's
approaches or a combination of these. Quantitative valuation
internal processes. Even this question is not requesting to
measures the impact of the negative/positive externalities on
report the methodology that has been used, a list of the most
societal stakeholders (e.g., society at large, local
well-known methodologies and standards that companies
communities, end users/consumers) and/or the environment
use for external impact measurement, management, and
(e.g., natural capital) in quantitative, non-monetary terms.
disclosure can be found here as a reference:
Monetary valuations measure the impact of the
negative/positive externality caused in monetary terms (e.g.,
• Social & Human Capital Protocol.
social costs of environmental damages caused).
• Business for Social Impact (B4SI).
• Socio-Economic Assessment Toolbox (SEAT).
Examples of environmental impacts
• Social Return on Investment.
•
• Impact Reporting & Investment Standards (IRIS).
- Improved/decreased quality of the air and water
• Other third party-methodology.
and associated health impact,
• Company internal methodology.
- Increased/ decreased availability and quality of
food,
Impact Metric: This is the quantitative (monetary or non-
- Improved adequacy of sanitation and associated
monetary) metric used to measure the impact caused on
social benefits,
external societal stakeholders or the environment. It converts
- Increased physical safety,
the output metric into a quantitative impact metric by
• A change in the natural earth system:
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evaluating the impact of the external damage or benefits • In case the specific impact is caused by more than
(negative/positive externalities) for societal stakeholders or one output, companies should specify all the
the environment. Note that the output and impact metrics are relevant metrics.
directly linked with each other, and with the material issue • Metrics already reported in other CSA questions
assessed, but the metric/unit used cannot be the same. (e.g., emissions, waste, biodiversity, community
impact), will only be accepted as long as there is a
Example of quantitative metrics: clear reference to the external impact dimension in
• Quality of life improvement: % increase in self- previous question (e.g., importance of the topic to
confidence society, preservation of natural capital, contribution
• Quality life years gained from a new medical to SDGs, impact on climate change, etc.) and an
treatment vs. the standard of care impact metric linked.
• % reduction in chronic illnesses due to the
Impact Valuation
• % Loss of productive and habitable land • Supporting evidence to validate that an impact
• % Loss of production in fisheries due to the spill of valuation has been conducted is required in the
pollutants in rivers form of private or public document(s) or a
• % Health-Adjusted Life Years (HALYs) comprehensive company comment.
• The supporting evidence is expected to provide an
Example of monetary metrics: explanation of how the output generated by the
• Social cost of carbon company due to its business activities translates
• Social cost of water into externalized societal or environmental impact.
• Social cost of waste Impact metric
• Social cost of alcohol • In case the company has quantified (in monetary or
• Cost of quality life year gained from a new medical non-monetary terms) the external impact generated
treatment vs. standard of care on societal stakeholders or the environment, this
• Cost of work-related stress to society option can be ticked. In the comment box, the
quantitative impact value and unit of measurement
are expected to be provided.
Data requirements
• The impact metric is required to be directly linked to
Output Metric the output metric and the impact valuation
• Companies clearly specify at least one quantitative conducted.
environmental or social output metric directly Not acceptable Impact metrics:
linked to the material issue identified, associated • Pure economic and financial metrics: GDP growth,
external stakeholder group impacted and the Tax payments, Net income, Amortization &
depreciation, Interest, Salaries, Own employment,
Taxes (direct income tax, indirect taxes & duties),
• Supporting evidence is required linking the output Economic Value Add or Gross Value Add.
metric to the material issue for external • Impacts due to philanthropic activities.
stakeholders. As an example: if the company is •
tracking its waste diverted from landfill (as a (including occupational health and safety metrics,
percentage or in metric tons), this is not sufficient employee training, employee benefits and salaries,
unless a link to its external impact on the etc.).
environment or societal stakeholders is clearly • Metrics on resource usage reductions or avoided
established in the supporting evidence (i.e. private emissions, as these are output metrics.
or public documents or comprehensive comment). • Social and Environmental Impact Assessments
• If one or both Material Issues in the question conducted for specific projects only.
• Metrics that are not linked to the output metric and
acceptable, the output metric associated with the the material issue.
material issue identified by the company is also not
acceptable due to the missing link between the
Disclosure requirements for partially public
material issue and its external impact aspects.
question:
• For acceptable output metrics, the check box
should be marked, and the specific value and unit of All qualitative information required in this question needs to
the output metrics provided in the text box. be supported by attached private or public document(s) or a
Companies may choose to provide additional comprehensive company comment. Options that cannot be
supporting evidence in the form of an explanation. verified in supporting documents will be unticked.
60 / 252
World Business Council For Sustainable Development
Additional credit will be granted for relevant publicly (WBCSD):
available evidence covering the following aspect of the https://www.wbcsd.org/Programs/People-and-
question: Society/Tackling-Inequality/Resources/WBCSD-Measuring-
• Quantitative impact metric linked to the material Impact
issue for external stakeholders https://docs.wbcsd.org/2017/05/IVR_Impact_Valuation_Whit
e_Paper.pdf
Business for Societal Impact B4SI, (formely London
References
Benchmarking Group LBG):
Natural Capital Protocol https://b4si.net/framework/
https://naturalcapitalcoalition.org/protocol/ Social Return on Investment (SROI)
https://naturalcapitalcoalition.org/wp- https://www.socialvaluelab.org.uk/wp-
content/uploads/2016/07/Framework_Book_2016-07-01- content/uploads/2016/09/SROI-a-guide-to-social-return-on-
2.pdf investment.pdf
Social & Human Capital Protocol Impact Reporting & Investment Standards (IRIS)
https://capitalscoalition.org/capitals-approach/social- https://iris.thegiin.org/
human-capital-protocol/ Impact Management Project
Social Value UK https://impactmanagementproject.com/
https://www.socialvalueuk.org/
https://www.socialvalueuk.org/resource/discussion-
document-valuation-social-outcomes/
https://www.socialvalueuk.org/app/uploads/2017/11/Discus CSRD - ESRS 2 MDR-M 77c, ESRS 2 SBM-3 48a
sion_Paper_on_SVP_NCP-FINAL-VERSION-2-1.pdf WEF Metrics - Total social investment ($)
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Risk & Crisis Management
Effective risk and crisis management is vital for long-term and incentivizing, training and empowering employees to
financial planning and organizational flexibility. Since the develop an effective risk culture. Additionally, we perform a
financial crisis, it has become particularly important. real-time check to assess the system with our internal MSA
Companies need to implement internal control processes to (Media and Stakeholder Analysis). The scope of the criterion
comply with existing regulations and proactively develop
control mechanisms. These questions focus on risk structure.
governance, the frequency of risk reviews, emerging risks,
Risk Governance
Assessment Focus
Question Rationale
The purpose of this question is to assess the effectiveness of The three lines of defense model is a recognized governance
a company's risk governance framework. For this, it is framework for managing risks. It lays out clear risk
important that the company's senior management and board management responsibilities and accountabilities to ensure
of directors are not just aware of risks but also actively that a company´s risk-related objectives are achieved. In this
involved in managing them. While the board of directors is model, the first and second lines are responsible for
ultimately responsible for risk management, it is up to the executing and monitoring risk management activities. The
senior management to take the board's strategic direction third line operates independently to check how well the risk
and turn it into appropriate policies and procedures, and to management processes are working.
effectively implement, execute, and monitor these policies.
Question Layout
Does the company have a risk governance framework in place and is it available publicly?
□ Yes, the company has a risk governance framework. Please indicate where this information is available in public reporting or
corporate website.
The company has a risk governance framework with board level risk oversight:
 Dedicated role or committee at board level for risk oversight (Independent and/or non-executive Board member(s))
The company has a risk governance framework with dedicated operational risk management functions in place:
 Operational Risk ownership (first line): Front-line employees or dedicated operational roles (e.g., risk managers, business
unit heads) own and manage risks.
 Risk Management and Compliance Oversight (second line): dedicated role(s) or committee(s) exist(s) at the senior
management or executive level, which is responsible for setting control standards and oversees compliance with them
(does not include the CEO).
 Independent Audit Unit (third line): An internal audit function that provides independent assurance on the effectiveness of
risk management and compliance processes.

Board Level responsibility: A dedicated role or committee at tasked with explicit responsibility for risk management
the highest governing body consisting of independent and/or overview. For two-tier boards, the board-level committee
non-executive Board member(s). This could be a Risk must be formed of members of the supervisory board.
Committee or an Audit Committee
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Operational Management Functions (Three Lines of Defense internal audit or a comparable external function, providing an
Model) independent assurance that organizational practices are
aligned wit
Operational Risk Ownership (first line): The employees or implemented by the first and second lines. The independence
teams directly involved in producing and/or delivering of this unit ensures objective monitoring and control of
products and services to clients. They are responsible for various risks, safeguarding the organization´s interests
owning and managing risks in the day-to-day operations. The without conflicts of interest arising from other business
first line is responsible for the execution of controls set by the priorities. This function typically reports directly to the board
second line. We expect clear assignment of risk management of directors on top of senior/executive management and
responsibilities at the business unit level, which could remains separate from the implementation of processes or
include roles such as Risk Owners, Risk Managers and risk management to preserve its objectivity.
Business Unit Heads.
Note: The responsibilities of internal audit as part of the third
Risk Management and Compliance Oversight (second line): line of defense extend beyond financial reporting compliance
The individual, committee(s) or body(ies) in the organization audits.
charged with monitoring and supporting risk management
processes, ensuring that risk management objectives are
Data Requirements
achieved. This oversight typically falls under senior
management or the executive level, responsible for setting To answer this question, it's important to focus on the
control standards and overseeing compliance. The second
line responsibility may be split into several sub-functions, framework, rather than responsibilities defined in specific
related to risk type for example, from a main/group function sections of the report such as Occupational Health & Safety,
in charge of monitoring risk. However, we expect that specific Human Rights or Climate Change.
sub-functions report into an overarching role or main function
as defined by the company. For two-tier boards, risk Disclosure Requirements
management responsibility as the second line of defense can
be at the management board level. Examples of responsible • The document(s) you attached will be used to verify
people or committees include the Chief Risk Officer, Risk your response. The supporting documents need to
Management Committee and Chief Compliance Officer. Note: be available in the public domain (e.g., annual
Given that the CEO has ultimate responsibility for all aspects report, sustainability report, integrated report,
of a company's operations, the CEO is not accepted here, but company publications) or corporate website.
rather the expected function would report to senior • Any response that cannot be verified in the attached
management or the CEO. document(s) will not be accepted.
Independent Audit Unit (third line): The unit tasked with References
advising and auditing to ensure policies are followed and
processes are executed in line with management's selected COSO Framework
performance goals and risk tolerances. This could be an The institute of Internal Auditors
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Risk Management Processes
Assessment Focus
Question Rationale Conducting robust risk assessments including evaluating risk

exposure and determining risk appetite allows companies to
The purpose of this question is
respond strategically to events that may have a material
management practices and strategies, essential for fostering
impact. Moreover, regular and frequent risk reviews and
an effective risk culture. Effective risk and crisis management
audits can enhance the effectiveness of risk management
are vital for long-term financial stability and adaptability.
processes. To embed these practices into the wider
Implementing internal control processes ensures compliance
organization, measures should be taken to educate and
with current regulations and positions a company to
incentivize employees at all levels of the business, thereby
proactively refine these controls.
nurturing a strong and effective risk culture. Such an
approach ensures that risk management is not just a
compliance exercise but a fundamental part of the company's
operational mindset.
Question Layout
Does the company have risk management processes and strategies to promote an effective risk culture and is it available publicly?
□ Yes, the company has risk management processes and strategies to promote an effective risk culture. Please indicate
where this information is available in public reporting or corporate website.
Risk Review
Aspects of our risk review process include the following:
 Description of the company-specific risk exposure (considering likelihood and magnitude) of at least two identified risks
 Description of process or framework to determine the risk appetite for identified risks
 Description of mitigating actions for at least two identified risks
Risk Exposure
We review our company's risk exposure on a regular basis. Please attach evidence of the frequency of the assessments:
 At least twice a year or more frequently
 At least yearly
 Less frequently than yearly
 Not specified
Risk Management Process Audit

We have conducted an audit of the risk management process. Please specify if an internal audit and/or an external audit have been
performed:
 Yes, we have conducted an internal audit in the last two years

 Yes, we have conducted an external audit in the last two years
Risk Culture
We have strategies in place to promote an effective risk culture throughout the organisation:
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 Regular risk management education for all non-executive directors
 Focused training throughout the organization on risk management principles
 Incorporation of risk criteria in the development of products and services
 Financial incentives which incorporate risk management metrics
Risk Review: A risk review is a process that involves guidelines on management systems audits or risk
identifying risks and assessing or reassessing their impact management standards such as ISO 31000 and should be
and likelihood. This process includes updating the status of conducted at least every two years. Audits related to internal
various risks and implementing procedures to identify controls of financial reporting and statements of commitment
hazards, determine potential negative effects. This may are not considered sufficient here. The frequency of audits
include stress testing, sensitivity scenario analyses. We should be clearly reported.
expect risk exposure to be reported for at least two of the
identified risks. Promotion of an effective risk culture: Creating a strong risk
culture is important for integrating risk processes,
The elements that define a risk review and are considered procedures and employee awareness throughout the
best practice include:
organization. This can be achieved by:
1. Description of the company-specific risks exposure: This • Regular risk management education for non-
should at least evaluate the potential magnitude and executive directors: Education of board members
likelihood of materialization of the risk, considering the should be recurring and specific to risk
factors unique to the business or industry in order to define management. This is different from regular risk
the impact of the risk on the company, e.g., stress testing, reporting to the board.
scenario analysis and sensitivity analysis are measures to • Providing training to all employees: Training must
assess the magnitude of impact when risks materialize but do cover risk management and be provided at a group
not necessarily give an indication of likelihood of level.
materialization. • Considering risk factors when developing new
products or services: Risk criteria can be linked to
2. Process or framework to determine risk appetite: There financial risks, regulatory risks, operational risks,
should be a clearly defined process or framework outlining etc.
the risk appetite (the level of risk it is willing to • Offering financial incentives tied to meeting risk-
accept) for the identified risks including who within the related goals: Incentives should be related to
organization is responsible for this. specific risks the company has identified as key
concerns. For instance, if health and safety or
3. Description of mitigating actions: Actions taken to reduce governance are noted as primary risks, incentives
the severity of the risk and the likelihood of potential negative could be connected to these areas.
impacts should be described. We expect mitigating actions to
be reported alongside at least two of the identified risks for Data Requirements
which the company has described specific risk exposure for.
To answer this question, it's important to focus on the
Review of risk exposure: Regular reviews are essential to
keep up with changes in the risk landscape that could affect review, rather than specific areas such as: Occupational
the company's risk exposure. These reviews help the Health & Safety, Human Rights or, Climate Change. Reports
organization stay resilient against potential risks. They such as those from the Task Force on Climate-related
ensure that the designated risk appetite and mitigating Financial Disclosures (TCFD) or the Carbon Disclosure Project
actions stay up-to-date and relevant. The mere reporting of (CDP) are not considered suitable evidence in this context.
risk exposure indicators, e.g., in the annual report is not However, if climate change is identified as a significant
considered sufficient evidence of an active risk exposure material risk, we would expect it to be reported in the
review process. overarching risk section.
Audit of risk management processes in the last two years:

This involves a systematic assessment of the methods, tools,
and processes used in identifying, evaluating, controlling, • The document(s) you have attached will be used to
monitoring, and reporting risks. Per best practice, audits can verify your response. The supporting documents
be conducted by qualified, internal auditors and by qualified, need to be available in the public domain (e.g.,
independent third-party auditors. These audits should follow
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annual report, sustainability report, integrated Standards & Frameworks
report, company publications) or corporate website.
CSRD - ESRS 2 GOV-1 23a AR 5, ESRS 2 GOV-2 26b, ESRS 2
IRO-1 53c i.
document(s) will not be accepted.
ESG Disclosure Standards (China) - G.2.1.1 Compliance
management system, G.2.2.1 Risk management system,
G.2.3.1 Audit system and implementation, S.3.2.2 Significant
References
risks and impacts
COSO Framework WEF Metrics - Integrating risk and opportunity into business
ISO 31000:2018 Risk Management process
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Emerging Risks
Assessment Focus
Question Rationale
It is important for investors to understand the long-term risks show their ability to plan effectively for long-term risks.
that companies face along with companies' awareness of the Reporting on long-term risks, their impacts on their business,
impacts of these risks on their business and any mitigating and the mitigating actions they are taking can improve
actions that they may be taking in response to such risks - investors' confidence in management's ability to plan
beyond the ongoing operational risks reported by most effectively for long-term challenges and therefore may make
companies. In disclosing these risks to investors, companies the company a more attractive long-term investment.
Question Layout
Please indicate two important long-term (3-5 years+) emerging risks that your company identifies as having the most significant
impact on the business in the future, and indicate any mitigating actions that your company has taken in light of these risks. For each
risk, please provide supporting evidence in your reporting for the description of the risk, the business impact and any mitigating
actions, and choose the category to which the risk belongs.
Emerging Risk 1 Emerging Risk 2
Supporting Evidence
Name of the Emerging Risk
Category
Description
Impact
Mitigating Actions

Emerging risks: The focus should lie on the most significant the past. Therefore, there is a lack of knowledge/preparation
emerging risks that are expected to have a long-term impact when it comes to managing the potential risk.
on the company and that are explained in public disclosures.
Risks that are considered to be acceptable here include any Impact on the business: It is not expected that a precise
newly identified risks that are expected to have a long-term financial impact of these risks on the business can already be
impact on the company's business, although in some cases calculated or estimated, but rather a convincing description
they may have already begun impacting the company's of how these emerging risks could impact the business, and
business today. A risk, by definition, has not materialized. require the company to adapt its strategy and/or business
However, an emerging risk in addition to not having model.
materialized, is unprecedented and has not been handled in
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Risk categories: The risk categories available in the dropdown control. Sources of these risks include natural,
menu are aligned with the categories defined in the World geopolitical or macroeconomic factors, but exclude
Economic Forum Global Risk Report. The categories are: operational, reputational or market risks.
Economic, Environmental, Geopolitical, Societal and • The risk and its impact on the company are specific.
Technological. While we acknowledge that that five For example, long-term risks like macroeconomic
categories above might not be exhaustive, the category developments should be described in the context of the
business environment that the company operates in
that are industry specific. Categories such as operational risk, (i.e., the specific regulations or laws that may be
compliance risk, reputational risk, competition risk, or market introduced) and the impact on the company should be
risk are not acceptable. specific (i.e., not simply the description of the overall
impact on the industry).
• The risk and its impact are publicly disclosed with the
Data Requirements
exception established for non-listed companies.
Because the disclosure of long-term emerging risks (beyond
operational risks commonly reported by companies or As a result, climate change, for example, would not be an
required by regulators) is so important for long-term acceptable emerging risk since it is an issue that has been
investors, the risks provided in this question should significantly impacting the business environment for a
correspond to risks that are disclosed publicly (e.g., annual number of years and that companies would have prepared for.
report, sustainability report, integrated report, company
publications, corporate website, risk reports). Additional The mitigating actions have to be reported together with the
specifications related to the description of the risk, the risk and its impact, as a response to the risk.
business impact, and mitigating actions not available in the
public domain will not be considered.
a) Emerging risks reported in this question have to be part of Listed and/or publicly owned companies are required to
the broad, cross-functional and general risk assessment provide links to public reports or corporate websites.
exercise of a company, therefore we would not accept risks
identified as part of a specific risk assessment exercise Non-listed companies are required to provide the following
(Human Rights risk assessment, OHS risk assessment, evidence, depending on the type of company:
climate risk assessment, etc.). • Family-owned companies and Privately owned
b) The same risk cannot be reported for more than 3 years in a corporate websites, or internal documents.
row. Similarly, if the company has been reporting the same • Cooperatives are required to provide public
risk in its public disclosure for more than 3 years, it is not reports, corporate websites, or internal documents.
considered emerging anymore. • State-owned companies are required to report on
their risk management in the public domain as their
c) An emerging risk needs to fulfill the six below requirements key stakeholder is the general public.
in order to be accepted:
• The risk is new, emerging
References
• The potential impact of the risk may be unknown and
is long-term, i.e., the risk is unlikely to have a World Economic Forum The Global Risks Report
significant immediate impact on the company, but
potentially may have begun to have consequences for Standards & Frameworks
the company today.
• The potential impact of the risk is significant, i.e., it has CSRD - ESRS 2 GOV-2 26c, ESRS 2 MDR-A 68a, ESRS 2 MDR-
A 68a AR 22
operations and may require the company to adapt its ESG Disclosure Standards (China) - G.2.2.2 Major risk
strategy and/or business model. identification and prevention
• The risk is an external risk, i.e., it arises from events WEF Metrics - Integrating risk and opportunity into business
outside the company that are beyond its influence or process
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Business Ethics
Business ethics are at the crux of a well-functioning The criterion evaluates the Codes of Conduct, their
business. By establishing integrity across business lines and implementation and the transparency surrounding reporting
amongst employees, trust can be built with key stakeholders, on breaches.
and employees and the general public can be safeguarded.
UN Global Compact Membership
Assessment Focus
Question Rationale
The UNGC is a reference point for investors to apprehend yearly release of a Communication on Progress. Therefore,
which companies are truly committed to a sustainable this question aims to verify whether companies have taken
growth. Indeed, being a participant/signatory of the UNGC this important public stance, regardless of their size.
Question Layout
Is the company a signatory/participant of the UN Global Compact and is this information available publicly?
□ Yes, the company is a signatory/participant. Please indicate where this information is available in public reporting or
corporate website.
□ No, the company is not a signatory, but its parent company is a signatory/participant. The information is publicly available.
Data Requirements References

United Nations Global Compact
participation in the UNGC in the public domain. Please, attach https://www.unglobalcompact.org/
a public letter of commitment or Communication
on Progress.
Please note that we also accept a link to the list of active SASB EM-EP-510a.2, EM-SV-510a.2
members on the UNGC website where we can verify the name
of your company.
Taiwanese companies not already members of the UNGC

should select Not Applicable and provide explanations in
the comment box.
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Codes of Conduct
Assessment Focus
Question Rationale
Codes of Conduct are corporate documents outlining a Conduct are voluntary but often seen as an important part of
company's values, principles and guidelines in a variety of company culture, reputation and compliance. With this
areas. Ideally, codes combine aspirations and detailed question, we assess the existence and scope of a company's
standards on how to put them into practice, guiding the way Code of Conduct.
the company conducts its business activities. Codes of
Question Layout
Does the company have a code of conduct at a group level (including subsidiaries) and is it available publicly?
□ Yes, the company has a group-wide code of conduct and it covers the following aspects. Please indicate where this
 Corruption and bribery

 Discrimination
 Confidentiality of information
 Conflicts of interest
 Antitrust/anti-competitive practices
 Money-laundering and/or insider trading/dealing
 Environment, health and safety
 Whistleblowing
Data Requirements
Please be aware that Codes of Conduct can come in different
formats and have different names (e.g., internal rules, CSRD - G1-1 10a, G1-3 19, S1-1 19, S1-1 24a, S1-3 32b
company's credo, compliance codes, ethics codes, codes of ESG Disclosure Standards (China) - G.2.6.1 Code of Business
practice, charter). Ethics and Code of Conduct
GRI Disclosure - 11.20
IRIS+ - OI2330, OI2596, OI5102
SASB - EM-EP-510a.2, EM-SV-510a.2, FN-AC-510a.2, FN-
This question requires supporting evidence from the public CB-510a.2, HC-DI-510a.1, HC-DR-230a.1, IF-EN-510a.3, RT-
domain. The information provided has to be included in your EE-510a.1
public reporting (e.g., annual report, sustainability report, SFDR Principal Adverse Impacts - Social and employee
integrated report, company publications, separate fuel matters
efficiency strategy document) or corporate website. UNGC Questionnaire - G3
UNGP - A1, A2, A2.3, C6.1, C6.2, C6.3
Any response that cannot be verified in the attached public
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Corruption & Bribery
Assessment Focus
Question Rationale
Corruption and bribery are economic crimes that are introduces, it creates uncertain consequences for investors,
and therefore increases the risk premium a company must
as its reputation, staff morale, or business relationships). pay for debt or equity. This question assesses the anti-
Companies doing business in countries with weak anti- corruption and bribery policy a company has in place to
corruption and bribery laws are exposed to additional complement legal requirements (or to compensate for the
reputational and legal risks. lack of such requirements in certain countries). Because
political and charitable contributions can be used as
Evidence of corrupt practices can result in a company's subterfuge for bribery, they should be explicitly covered by
exclusion from contracts financed by institutions that the anti-corruption policy and should be publicly disclosed.
blacklist bribe suppliers (for example, the World Bank's list of
debarred firms), potentially affecting the company's future
earnings. Due to the additional types of risk that corruption
Question Layout
Does the company have a policy on anti-corruption and bribery at a group level (including subsidiaries) and is it available publicly?
□ Yes, the company has a group-wide policy on anti-corruption and bribery and it covers the following aspects. Please
indicate where this information is available in public reporting or corporate website.
 Bribes in any form (including kickbacks) on any portion of contract payments or soft dollar practices
 Direct or indirect political contributions
□ Political contributions publicly disclosed. Please indicate web address:
 Charitable contributions and sponsorship
□ Charitable contributions and sponsorship publicly disclosed. Please indicate web address:
money manager (a fund, investor, etc.) to its service

providers. Instead of paying the service providers with cash
Kickback: A kickback refers to a share of misappropriated (i.e., hard dollars), the investor pays in-kind (i.e., with soft
funds one organization pays another in a case of corrupt dollars) by passing on the business to its service providers.
bidding. This can occur in a business context or in any other
situation in which people are entrusted to spend funds that Political contributions and charitable donations: This
do not belong to them. In this context, a company would win a question specifically considers contributions and donations
contract in a public bidding process even if its provided quote that act as a means of bribery and corruption, and this needs
exceeds the market price or best offer. For the benefit of to be explicitly addressed in the attached policies. In the
having won the contract, the provider of the service then pays context of this question, disclosure of details of contributions
a kickback (for example, the difference between the and donations is only considered for topics that are
overvalued and the actual market price, or part of this specifically covered in the relevant policy, such as the
difference) to the buyer. company Codes of Conduct or a separate anti-corruption and
bribery policy.
Soft dollar: The term soft dollar is used in the finance
industry and refers to in-kind payments made by a Other aspects related to political contributions and charitable
donations that are not linked to bribery or corruption are
addressed in other parts of the questionnaire.
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Data Requirements United Nations Convention Against Corruption, 2003
Business Principles for Countering Bribery, 2013 (by
Transparency International)
public reporting (e.g., annual report, sustainability report,
integrated report, company publications, corporate Standards & frameworks
citizenship/corporate social responsibility report) or
CSRD - G1-1 10b, G1-3 18a AR 5-AR 6, G1-3 19, G1-5 29b i. AR
corporate website.
9-AR 10
Please ensure that the marked options are both covered by
ESG Disclosure Standards (China) - G.2.6.3 Measures to avoid
your company's policy and are clearly disclosed in the
violations of business ethics
attached documents.
SASB - EM-EP-510a.2, EM-SV-510a.2, IF-EN-510a.3, RT-EE-
510a.1
References UNGC Questionnaire - AC2, G2
OECD Convention on Combating Bribery of Foreign Public

Officials in International Business Transactions, 1997
72 / 252
Code of Conduct: Systems/Procedures
Assessment Focus
Question Rationale
As with every strategy or goal, a code of conduct is only as assure employees, creditors, business partners, shareholders
good as the level that it is complied with. A company and other stakeholders that internal systems will not be co-
therefore needs to have proper systems and procedures in opted, circumvented or overridden.
place to ensure the implementation of its code of conduct to
Question Layout
Does the company have mechanisms in place to ensure effective implementation of its code of conduct and are they available
publicly?
□ Yes, the company has mechanisms in place to ensure effective implementation of its codes of conduct. Please indicate
where this information is available in public reporting or corporate website.
Aspect: Please provide supporting evidence for the aspect and
indicate page numbers:
□ Responsibilities, accountabilities and reporting lines are
systemically defined in all divisions and group companies
□ Dedicated help desks, focal points, ombudsman, hotlines
□ Compliance linked to employee remuneration
□ Employee performance appraisal systems integrates

compliance/codes of conduct
□ Disciplinary actions in case of breach, i.e. warning, dismissal,
zero tolerance policy
□ Compliance system is certified/audited/verified by third party.
Please review the additional information and question
guidance banner for further detail.
Data Requirements report, sustainability report, integrated report,

company publications) or corporate website.
Third-party verification: For the
certification/audit/verification of the compliance system,
public document(s) will not be accepted.
only independent third parties are accepted. Internal audit is
not considered an independent third party. A third-party
review must cover the company's codes of conduct and
compliance systems for enforcing these codes, including
tracking and reporting of breaches. Third-party assurance on CSRD - G1-1 10a, G1-1 10c i., G1-1 10c ii., G1-3 18a AR 5-AR
other financial data or sustainability reporting is not accepted 6, G1-3 18c, G1-3 19, S1-1 19, S1-3 32c
here. ESG Disclosure Standards (China) - G.2.3.3 Complaint and
reporting system and implementation, G.2.6.1 Code of
Supporting evidence: Business Ethics and Code of Conduct
• This question requires supporting evidence from the GRI Disclosure - 2-26
public domain. The information provided has to be IRIS+ - OI3601
included in your public reporting (e.g., annual SASB - EM-EP-510a.2, EM-SV-510a.2
UNGC Questionnaire - AC1, G4, G5, G8
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UNGP - A2, A2.3, C6, C6.1, C6.2, C6.3
WEF Metrics - Protected ethics advice and reporting
mechanisms
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Reporting on Breaches
Assessment Focus
Question Rationale
Organizations are increasingly expected by the marketplace, transparent corporate reporting to all stakeholders. This
international norms, and stakeholders to demonstrate their question assesses the transparency a company shows in
adherence to integrity, governance, and good business relation to breaches of its codes of conduct or anti-corruption
practices. Reporting to authorities is mandatory in many & bribery policies towards its stakeholders, both for the
countries but our questions are looking for evidence of occurrence of incidents as well as the company's response.
Question Layout
Does your company publicly report on breaches (e.g. Corruption, Discrimination etc.) against your codes of conduct/ethics? Please
specify where this information is available in your public reporting or corporate website.
□ Yes, we publicly report breaches of the Codes of Conduct
□ We report on following areas
Reporting areas Number of breaches in FY 2023
Corruption or Bribery
Discrimination or Harassment
Customer Privacy Data
Conflicts of Interest
Money laundering or Insider trading
□ We report breaches on a combined basis for all areas in the Code of conduct
□ We report breaches on a combined basis, but only for some areas in the Code of conduct
□ We report that no Codes of Conduct related breaches have occurred during the most recent reporting cycle
Question-Specific Guidance & Definitions authorities that are not publicly available to all stakeholders
will not be considered here.
Customer Data Privacy: Data breaches relative to the
If the company discloses just the total number of breaches
customer. This can be defined as the accidental or unlawful
for all aspects of the code of conduct (Without breakdown)
destruction, loss, alteration, unauthorized disclusre of, or
then the second option report on total number of
access to, personal data transmitted, stored, or otherwise
cases/breaches but do not report on specific should be
processed. This can include, but is not limited to, the
selected.
disclosure of customer personally identifiable information,
theft of customer financial information, healthcare data and
In case, while reporting a company has clubbed some areas of
more.
breaches then the third option, 'We report breaches on a
combined basis, but only for some areas in the Code of
Data Requirements
conduct' will be marked.
Disclosure on various aspects of code of conduct related
breaches is assessed in this question such as Corruption, If there were no code of conduct breaches, the fourth option
Discrimination, Privacy, Insider Trading etc. Filings to "We report that no Codes of Conduct related breaches have
75 / 252
occurred during the most recent reporting cycle" should be Business Principles for Countering Bribery, 2009 (by
chosen and indicate where this is publicly reported. Transparency International, second edition)
The absence of breaches needs to be publicly disclosed for
the purpose of this question and an indication of where this is
publicly reported should be given. A comment indicating that
no breaches occurred and that reporting would have been CSRD - G1-4 26, S1-17 103a AR 103-AR 106, S1-3 32e AR 32
available in the event of such breaches occurring is not ESG Disclosure Standards (China) - G.2.1.4 Customer privacy
sufficient for this question. protection
GISD - Information Technology (IT): Frequency of data privacy
Supporting evidence incidents, Total number and nature of incidents of corruption
• This question requires supporting evidence from the confirmed during the current year, related to this year
public domain. The information provided has to be GRI Disclosure - 2-27, 205-3, 406-1, 418-1
included in your public reporting (e.g., annual IRIS+ - OI2165, OI9379
report, sustainability report, integrated report, SASB - CG-EC-230a.2, CG-MR-230a.2, FB-FR-230a.1, FN-AC-
company publications or corporate website). 510a.1, FN-CB-230a.1, FN-CB-510a.1, FN-CF-230a.1, FN-EX-
• Any response that cannot be verified in the attached 510a.2, HC-DR-230a.2, HC-MC-230a.2, RT-AE-230a.1, RT-AE-
public document(s) will not be accepted. 510a.1, SV-AD-220a.3, SV-ED-230a.3, SV-PS-230a.3, TC-IM-
220a.3, TC-IM-230a.1, TC-SI-230a.1, TC-TL-230a.1
References SFDR Principal Adverse Impacts - Cases of insufficient action
taken to address breaches of standards of anticorruption and
OECD Convention on Combating Bribery of Foreign Public
antibribery, Governance
Officials in International Business Transactions, 1997
UNGC Questionnaire - AC5
UNGP - C5.1
United Nations Convention Against Corruption, 2003
WEF Metrics - Anti-Corruption, Discrimination and
Harassment Incidents (#) and the Total Amount of Monetary
Losses ($)
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Policy Influence
Although companies legitimately represent themselves in In this criterion we evaluate the transparency of c
legislative, political and public discourse, excessive disclosures on the amounts they contribute to political
contributions to political campaigns, lobbying expenditures campaigns, trade associations and other tax-exempt groups,
and contributions to trade associations as well as the lack of and on lobbying expenditures. Additionally, we assess the
transparency about those contributions may damage management systems companies have in place to ensure
lobbying activities and memberships of trade associations are
Perc tments aligned with the Paris Agreement to limit global warming to
to combat climate change and its lobbying activities can also well below 2 degrees Celsius.
damage its reputation, and significantly undermine global
efforts to transition to more sustainable economies.
Contributions & Other Spending
Assessment Focus
Question Rationale
Although companies legitimately represent themselves in of corruption. With this question, we assess the total amount
legislative, political and public discourse, excessive of money companies are allocating to organizations whose
contributions to political campaigns, lobbying expenditures primary role is to create or influence public policy and the
and contributions to trade associations and other tax-exempt extent to which these amounts are disclosed to the public.
groups may damage compan
Question Layout
Please indicate your annual total monetary contributions to and spending for political campaigns, political organizations, lobbyists or
lobbying organizations, trade associations and other tax-exempt groups, as defined in the Info Text. If this information is publicly
reported, please provide supporting evidence or indicate the weblink below. PAC contributions by employees should not be included.
Please also indicate if these figures are provided in your public reporting.
□ We are able to itemize the figures. If you have not made any contributions for one or more items, please enter 0 and indicate
if this information is available in your public reporting:
Contributions to: FY 2020 FY 2021 FY 2022 FY 2023

Lobbying, interest representation or □ Information
similar available
publicly
Local, regional or national political □ Information
campaigns / organizations / candidates available
publicly
Trade associations or tax-exempt groups □ Information
(e.g. think tanks) available
publicly
Other (e.g.spending related to ballot □ Information
measures, referendums) available
publicly
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Total contributions and other spending □ Information
available
publicly
Data coverage (as % of denominator, Percentage of:
indicating the organizational scope of the ______
reported data) __________
□ We can only report the total spending figures. Please indicate the items included in your total spending figures. If an
item is not included, please select "not included". If you have not made any contributions for a specific category,
please select "No contribution." Please also indicate if these figures are provided in your public reporting.
Lobbying, interest representation or similar Information available

publicly
Local, regional or national political campaigns / candidates Drop-down menu: Information available
Included publicly
• Included
• Not included
• No contribution
• Not Known
Trade associations or tax-exempt groups (e.g. think tanks) Information available
publicly
Other (e.g. spending related to ballot measures or referendums) Information available
publicly
Currency FY 2020 FY 2021 FY 2022 FY 2023
Total Contributions and

other Spending
Data coverage Percentage of:
(as % of denominator) ______
___
□ We did not make any contributions to and spending for political campaigns, political organizations, lobbyists or lobbying
organizations, trade associations and other tax-exempt groups, as defined in the information button.
□ This information must be available in the public domain.
Data Requirements • Note: PAC contributions by employees should not be

included.
The company shall report its total monetary contributions to
political campaigns or organizations, lobbyists, trade
Source: SASB and GRI.
associations and other tax-exempt groups whose role is to
influence political campaigns or legislation. This includes all Disclosure requirements for partially public
direct and indirect spending, contributions or payments to: question: Additional credit will be granted for relevant
publicly available evidence covering at least one figure in the
• Political campaigns, ballots measures or referendums. last reported year. If no contributions were made for a
• Political organizations, trade associations or tax- specific item or category (e.g., zero political contributions in
exempt groups whose role is to influence political the last fiscal year), companies should publicly report this
campaigns or legislative activities, including chambers information. This should be publicly reported on the
of commerce, trade boards, and the like. This includes company's own website not via a third party website or on a
membership fees towards trade associations, industry transparency register. As this is a quantitative question, any
associations and business associations. non-public evidence is not required to support your answer
• Registered lobbyists and lobbying groups.
• Companies do not need to report the monetary value of and reference this in the confidential additional comments.
in-kind giving, employee volunteering or management
overheads related to the activities described above.
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Coverage should be reported as a % of total operations, company revenues, then 50% should be reported as
revenues, etc. as provided in the denominator question - coverage.
indicating whether the provided data represents the entire
organization or only parts of it. The percentage provided in the
coverage field should not represent spending as a % of total Standards & frameworks
spending or total revenues. CSRD - G1-5 29b i. AR 9-AR 10
GRI Disclosure - 11.22, 12.22, 14.24, 415-1
• For example, if the numbers reported are only for UNPRI - PGS 19
operations in the US, and the US represents 50% of
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Largest Contributions & Expenditures
Assessment Focus
Question Rationale
Although companies legitimately represent themselves in of corruption. In this question, we ask for the largest
legislative, political and public discourse, excessive contributions or expenditures to organizations whose primary
contributions to political campaigns, lobbying expenditures role is to create or influence public policy and assesses the
and contributions to trade associations and other tax-exempt extent to which this information is provided to the public.
groups may damage compan
Question Layout
Did your company make any contributions to or expenditures to political campaigns or organizations, lobbying, trade associations,
tax-exempt entities, or other groups whose role is to influence political campaigns or public policy and legislation? In this context, a
e, or
lease see the Information Button for examples. PAC contributions by employees
should not be included.
Please also indicate if this reporting is available in your public reporting.
If you made less than three contributions, please select "No contribution" under "Type of organization" in the appropriate row.
□ Yes, we made contributions or had expenditures. Please indicate where this information is available in the public domain.
Issues and Topics

Currency:___________
Issue or topic Corporate Position Description of Total spend in FY 2023

Position/Engagement
1. ______ Drop-down menu: 1. ______ 1. ______

Support
Support with minor exceptions
Support with major exceptions
Neutral
Oppose
Undecided
No contribution
2. ______ 2. Drop-down menu 2. 2.
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Other Large Expenditures
Name of organization, Type of organization Total amount paid in FY 2023

candidate or topic
3. _______ Drop-down menu: 3. ______

National political organization
State or local political campaign,
candidates or committees
Political Action Committee (PAC)
Lobbying, interest representation or
similar
Trade association
Tax-exempt group
Other: Please specify: ______
4. _______ 4. Drop-down menu 4.
5. _______ 5. Drop-down menu 5.
□ No, we did not make any contributions or have any expenditures

□ This information must be available in the public domain

Largest contributions: In this context, a "contribution" is the
aggregate amount given during the fiscal period to an There are two distinct aspects to this question: the two top
individual candidate, organization, ballot measure, or "issue issues and the three largest single contributions/payments.
area" or "topic" requiring lobbying efforts. For example: There may therefore be some overlap, if the spending on the
issues is done by the trade associations. If your largest
Sugar taxes: The total amount of lobbying expense for the contributions go to trade/business associations, our
fiscal period shall be reported as one line item. The expenses preference is that you are able to inquire with the trade
may have been related to several activities around the world: association(s) as to the percentage of your contribution
a ballot initiative in California, legislation being considered by allocated to lobbying for specific issues. If the trade
the US federal government and legislation pending in the UK. association cannot provide this level of detail, an estimate
will suffice. In the worst case, for the first part of this
Drug pricing: The total amount of lobbying expense for the question, we ask you to report your direct lobbying
fiscal period shall be reported as one line item. The expenses expenditures only, even if the amounts are small.
may have been related to several state ballot initiatives in the
US. Note: Please do not include contributions to charities whose
main purpose is something other than supporting specific
Data Requirements political parties or causes, e.g., they primarily provide
healthcare to an at risk population or food and shelter to the
poor.
political campaigns or organizations, lobbyists, trade
associations and other tax-exempt group, related to Disclosure requirements for partially public question.
individual candidates, organizations, ballot measure or Additional credit will be granted for relevant publicly available
referendum, or topic for which lobbying were contracted. This evidence covering at least three of the largest contributions
includes all contributions, donations and membership fees and expenditures described. This should be publicly reported
towards trade associations, industry associations and a third-party website or on
business associations. Companies do not need to report the a transparency register.
monetary value of in-kind giving, employee volunteering or
management overheads related to the activities mentioned
above. If local legislation prevents you from making political
provide an explanation in the company comment box.
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CSRD - G1-5 29b i., G1-5 29b i. AR 9-AR 10, G1-5 29c, G1-5 UNPRI - PGS 19
29c AR 14 WEF Metrics - Alignment of strategy and policies to lobbying
GRI Disclosure - 11.22, 12.22, 2-28
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Lobbying and Trade Associations - Climate Alignment
Assessment Focus
Question Rationale
As more and more companies commit to supporting the Paris their climate strategies and to take action when they do.
Agreement with net-zero targets and climate strategies, there Aligning lobbying activities and trade association
is increasing scrutiny from both investors and the public on memberships with the Paris Agreement helps protect the
the extent to which these public commitments are reinforced reputation of companies, and ensure action on climate
and not contradicted by the behavior of companies in change is consistent and strong.
lobbying. Trade associations can also be a powerful source of
influence on public policy. There have been successful This question asks about the processes companies have in
shareholder resolutions asking companies to disclose more place to oversee, review and disclose their climate-related
about their lobbying activities and trade association lobbying activities and trade association memberships, and
memberships related to climate change. Companies have a to ensure alignment of these with the Paris Agreement.
responsibility to ensure their memberships do not contradict
Question Layout
Does the company have a program to align its lobbying activities with the Paris Agreement and is it available publicly?
□ Yes, the company has a program to align its lobbying activities with the Paris Agreement. Please indicate where this
□ Management system in place for lobbying activities and trade association memberships.
□ Governance framework for public policy engagement with clear accountabilities up to executive level.
□ Statement of our position on public policies relating to climate change, which is aligned with the Paris Agreement.
□ Reviewing and monitoring process to assess whether public policy engagements and lobbying are aligned with the
Paris Agreement
□ For direct lobbying activities
□ For our trade associations
□ Clear framework for addressing misalignments between climate change policy positions of trade associations and our
own climate position
□ Reporting on:
□ Climate policy positions and activities of trade associations
□ Climate-related direct lobbying activities
The program covers:
□ All jurisdictions where we have operations
□ Most jurisdictions
□ Some jurisdictions only
Question-Specific Guidance & Definitions 2050 aligned. Examples of Paris-Aligned lobbying could be
supporting measures that promote the growth of renewable
Paris-Aligned lobbying: Lobbying and public policy
energies or supporting the introduction of a carbon price that
engagements that are Paris-Aligned are supportive of
is aligned with reaching net-zero by 2050.
legislation and regulation that will facilitate the achievement
of the Paris Agreement goal to limit global warming to well
Direct lobbying activities: This encompasses lobbying by
below 2 degrees Celsius. It could also be referred to as 2-
either in-house lobbyists or third-party lobbyists paid for or
degree or 1.5 degree aligned, science-based, or net-zero by
otherwise engaged by the company. Lobbying activities
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include direct communication and contact with lawmakers or This question requires public evidence.
regulatory institutions for the purpose of influencing
legislation, as well as responses to consultations and other This question can be marked Not Applicable only if all
engagements intended to influence legislation. contributions and spending on lobbyists and trade
associations are prohibited by law. Please note that evidence
Trade associations: may also be referred to as business or must be available in the public domain, and this must apply to
industry associations or groups. A trade association is a body, all jurisdictions where your company operates in order to be
normally with a membership structure that exists to accepted. If only one out of lobbying and trade association
represent the interests of a specific industry. Trade memberships is prohibited and not the other, please follow
associations can also exist on a cross-industry and national the approach below.
level, for example a national or regional chamber of
commerce. If your company either does not undertake any lobbying
activities, or is not a member of any trade association, in any
Review & monitoring process: A systematic process to assess jurisdiction, because one or the other is prohibited by law or
the alignment of lobbying activities with the Paris Agreement.
To be considered in this question, the processes must assess stated in the public domain, then the respective options can
stated positions on climate related legislation and regulation

if this is aligned with the Paris Agreement). For direct
lobbying activities, the review process ideally takes place
before lobbying has been conducted. For trade associations,
the review process can take place on a regular basis or References
whenever new associations are joined and should assess Guide for responsible corporate engagement in climate
whether the trade association supports the Paris Agreement policy, United Nations Global Compact Caring for Climate
through its lobbying and public policy engagements. Report
Global Standard on Responsible Corporate Climate Lobbying
Framework for addressing misalignments: Where Company lobbying and climate change: good governance for
ing Paris-aligned outcomes, Grantham Research Institute on
activities and the goals of the Paris Agreement have been Climate Change and the Environment
identified, companies should have an established framework Trade Associations and their Climate Policy Footprint,
for how they deal with this. The framework should include at InfluenceMap
least two of the following options: public statements
distancing the company from the misalignment, engagement
with the trade association with clear timelines and an
escalation process if unsuccessful, leaving the trade CSRD - G1-5 29a AR 12
association, or forming proactive coalitions to counter the SASB - EM-EP-530a.1, EM-RM-530a.1, EM-SV-530a.1, RT-
non-Paris-aligned lobbying. CH-530a.1
UNPRI - PGS 11.2, PGS 19
Data Requirements
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Supply Chain Management
In an increasingly globalized world, when a company Investors increasingly see the importance of supply chain risk
outsources its production, services or business processes, it management and the negative consequences if it is not
also outsources corporate responsibilities and reputational managed effectively.
risks. This means that companies need to find new strategies
to manage the associated risks and opportunities which differ This criterion aims to identify companies with lower supply
from the traditional risk and opportunity management with chain risk profiles, either through supply chain
the company's production or services in-house. In addition, characteristics or through appropriate management of
the company is confronted with the need to minimize costs existing risks. In addition, we seek to identify companies that
and time of delivery to satisfy customers' demand and are using sustainable supply chain management as an
increase profitability without negatively impacting product opportunity to improve their long-term financial performance.
quality or incurring high environmental or social costs.
Supplier Code of Conduct
Assessment Focus
Question Rationale
Companies not only outsource production, services, and A general supplier code of conduct summarizes and
business processes but responsibilities, risks, and represents the basic commitments a company requires from
opportunities as well. On one hand, outsourcing generally its suppliers. It also serves as a first information source for
tends to increase a company's flexibility, but on the other prospective suppliers. With this question, we assess if your
hand, supply chain risks might become less apparent, new company has a supplier code of conduct if it is public, and
dependencies may arise, and the identification, monitoring, what issues it covers.
and management of risks and opportunities in the supply
chain may become more difficult.
Question Layout
Does the company have a Supplier Code of Conduct and is it available publicly?
□ Yes, the company has a Supplier Code of Conduct covering the following issues. Please indicate where this information is
Human Rights and Labor

 Forced labor
 Child labor
 Working conditions (e.g., working hours, physical/ mental demands of the workplace, wages, benefits)
 Occupational health and safety
 Discrimination and harassment
 Freedom of associations and collective bargaining
Environment
 Greenhouse gas emissions and energy consumption
 Pollution prevention and waste management
 Resource efficiency
 Biodiversity, no deforestation, or land conservation
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Business Ethics
 Anti-corruption and conflict of interest
 Anti- competitiveness

Supplier code of conduct: It describes the principles, values, Discrimination: act and result of treating persons unequally
standards, or rules of behavior that guide the decisions, by imposing unequal burdens or denying benefits instead of
procedures, and systems of the supplier in a way that (a) treating each person fairly on the basis of individual merit
contributes to the welfare of its key stakeholders, and (b) based on their race, ethnicity, gender, sexual orientation, age,
respects the rights of all constituents affected by its nationality, religion, union status, and/or marital status
operations. It usually includes at least the 03 components:
Human Rights & Labour, Environment, and Business Ethics Freedom of association: the right of employees and workers
to form, join and run their own organizations without prior
Human Rights & Labour: This includes safeguards against authorization or interference by the state or any other entity
child labor, non-discrimination, health and safety, working
conditions, working hours, compensation, right to Collective bargaining: all negotiations which take place
association, and freely chosen employment. between one or more employers or employers' organizations,
on the one hand, and one or more workers' organizations
Forced labor: all work and service that is exacted from any (trade unions), on the other, for determining working
person under the menace of any penalty and for which the conditions and terms of employment or for regulating
said person has not offered herself or himself voluntarily. relations between employers and workers
Forced labor also includes human trafficking, which is the
recruitment, transportation, transfer, harboring, or receipt of Environment: This includes avoiding pollution, minimizing
persons by the use of threat or of force or other forms of emissions, and improving the resource efficiency of supplier
coercion, abduction, fraud, deception, abuse of power, or a operations and products throughout the lifecycle
position of vulnerability or of the giving or receiving of
payments or benefits to achieve the consent of a person Greenhouse gas emissions and energy consumption refer to
having control over another person, conducted for the emissions of the six main GHGs that are covered by the Kyoto
purpose of sexual exploitation, forced labor or services, Protocol, including carbon dioxide (CO2), methane (CH4),
slavery or practices similar to slavery, servitude or the nitrous oxide (N2O), hydrofluorocarbons (HFCs),
removal of organs. perfluorocarbons (PFCs), and sulfur hexafluoride (SF6).
Energy consumption refers to the purchase or production and
Child labor: is work performed by children that is mentally, use of energy from renewable sources (e.g., hydroelectric,
physically, socially, or morally dangerous and harmful to wind, solar, geothermal, bioenergy) and to the efficient use of
children, affecting their health and personal development, or energy by reducing the waste/loss of energy or upgrading
that interferes with their compulsory schooling. equipment with lower energy consumption.
Working conditions: cover a broad range of topics and issues, Pollution prevention and waste management refer to the
from working time (hours of work, rest periods, and work prevention and management/disposal of by-products in
schedules) to remuneration, as well as the physical business operations such as air pollutants (e.g.,particulate
conditions and mental demands that exist in the workplace matter, lead, sulfur dioxide, etc.), sewage, and solid waste
(including non-hazardous and hazardous waste).
Occupational health and safety: a set of interrelated or
interacting elements to establish an occupational health and Resource efficiency refers to organizational or technological
safety policy and objectives, and to achieve those objectives modification in designing product/process that allows more
efficient usage of raw materials or water.
Harassment: Harassment is defined as a course of comments
or actions that are unwelcome, or should reasonably be Biodiversity, no deforestation, or land conservation refers to
known to be unwelcome, to the person towards whom they the protection or promotion of natural habitats, biodiversity,
are addressed. Non-sexual harassment includes but is not or management of soil to avoid loss of nutrients, erosion, and
exclusive to mobbing and bullying, while sexual harassment land pollution. Some aspects might include, for example, A)
includes a sexual component. management of biodiversity risks by setting targets to offset
any losses (no net loss) or aims to achieve a net positive
impact on biodiversity; B) prohibition of supplier operations in
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sites containing globally or nationally important biodiversity; comprehensive company comment and/or public reporting
C) application of mitigation hierarchy (avoid, minimize, that it does not purchase goods or services for the purposes
restore & offset) if a company is operating in areas in close below. To be granted Not Applicable , the company must
proximity to critical biodiversity; D) land conservation efforts state they:
which include a variety of techniques such as contour
farming, mulching, crop rotation, etc. •
production processes, and
Business Ethics: refers to the policies and practices to ensure • Do not re-
the ethical conduct of the organization and associated customers, and
individuals in all business activities, including, but not limited • Do not utilize goods or services as capital goods
to, anti-corruption, anti-competitiveness, and conflict of (e.g.,
interest. operations.
Anti-Corruption: ed power for Industry-specific special cases:
organizations, including practices such as bribery, facilitation REI Equity Real Estate Investment Trust (REITs): companies
payments, fraud, extortion, collusion, and money laundering;
an offer or receipt of any gift, loan, fee, reward, or another as the main activity of the business in question '0.1
advantage to or from any person as an inducement to do
something that is dishonest, illegal, or a breach of trust in the question.
REM Real Estate Management & Development: companies

Anti-Competitiveness: refers to actions of the organization or
employees that can result in collusion with potential business in question '0.1 Denominator Area', should mark
competitors, with the purpose of limiting the effects of
market competition, including but not limited to cartel
activities, price fixing, and anti-trust activities. OIE - Energy Equipment & Services Industry: Services
Companies (consultancy or seismic surveying), should mark
Conflict of Interest: refers to a situation where an individual
is confronted with choosing between the requirements of his
or her function and his or her own private interests
References
Data requirements
Supply Chain Sustainability
Supporting evidence
• This question requires public documents.
• For options covering multiple topics, your Supplier Standards & frameworks
Code of Conduct must address all elements stated CSRD - E2-2 AR 13, E4-2 AR 12 a, E5-1 15(b), E5-1 AR 9 b, E5-
in the option. The only exception is Biodiversity, 2 20(e) AR 13, E5-2 AR 11, G1-2 15a AR 2-AR 3, S1-4 AR 35,
deforestation, or land conservation S2-1 18, S2-4 AR 30
Not Applicable General Rule IAST APAC - Core Modern Slavery Metrics
SASB - CG-TS-430a.2, EM-SV-510a.2, FB-PF-430a.2, FB-RN-
Not Applicable for this question (beyond the industries 430a.3, HC-DI-510a.1, RT-AE-510a.3
detailed below) will only be accepted for special cases. In UNGP - A1.3, A2, A2.4
such cases, the company must credibly explain via a
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Supplier ESG Programs
Assessment Focus
Question Rationale
Developing and deploying sound supplier ESG programs is a only need to have systems/procedures in place to track the
foundational strategic and operational activity for impact of ESG along their supply chains, but they also need to
organizations. ensure that these practices are routinely reviewed to ensure
that their business demands, and expectations, are in line
The purpose of this question is to evaluate whether with established ESG requirements. Suppliers which provide
companies have systems/procedures in place to ensure s production
effective internal implementation of the supplier ESG processes and suppliers providing goods and/or services
program and to identify and address material risks and (e.g., machines/infrastructures) that are used as operational
impacts resulting from supply activities. Clear and structured capital goods by the purchasing company must be covered in
governance, together with internal communication and these programs. Together with these supplier typologies,
training, are needed to ensure the correct plan, suppliers of indirect materials and/or office supplies can be
implementation, and improvement cycles. Organizations not included as well.
Question Layout
Does the company have
□ Yes, the company has measures to ensure effective implementation of supplier ESG programs. Please indicate where this
□ Oversight of implementation of the supplier ESG program is defined. Please select the highest accountable decision-making
body:
□ Board of directors
□ Executive management
□ Purchasing practices towards suppliers are continuously reviewed to ensure alignment with the Supplier Code of Conduct
and to avoid potential conflicts with ESG requirements.
□ Suppliers are excluded from contracting if they cannot achieve minimum ESG requirements within a set timeframe.
□ Suppliers with better ESG performance are preferred by applying a minimum weight to ESG criteria in supplier selection and
contract awarding.
□

Companies should make sure that this due diligence
approach is deployed also within the organization, to
Supplier ESG program
guarantee harmonization between ESG strategy for the
For businesses to identify, assess, and plan corrective
supply chain and the company's purchasing practices.
measures in relation to the sustainability of their supply
chains, it is crucial to implement a robust and comprehensive
Oversight of implementation: Strategic oversight to ensure
supplier ESG program. A supplier-focused ESG program is the
alignment of vision and implementation is critical to ensuring
collection of activities and measures that enables businesses
successful strategies and programs. This is also true for the
to recognize and assess potential ESG risks, and
supply chain ESG strategy and the supplier ESG program. To
consequently, plan remedial measures to assure solid
guarantee maximal priority and focus, this oversight should
sustainability performance along the supply chain.
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ideally sit on the board of directors. Alternatively, top Data Requirements
executive management is also acceptable as it can align ESG
• This question requires public evidence. Please
strategies of different divisions/functions and drive the
indicate where in your public reporting you report
organization to reach its sustainability goals. The CEO
information about the selected options.
individually is not acceptable as the CEO is ultimately
accountable for all areas of a company's operations.
Not Applicable General Rule
Review of purchasing practices to avoid potential conflicts

Not Applicable for this question (beyond the industries
with ESG requirements: Purchasing practices not only
detailed below) will only be accepted for special cases. In
include the choice of the material/part/product/service to be
such cases, the company must credibly explain via a
bought or the supplier from which to purchase the needed
comprehensive company comment and/or public reporting
items. They also include specific indications on costs and
that it does not purchase goods or services for the purposes
quality of the products, as well as delivery times. It is of
below. To be granted Not Applicable , the company must
paramount importance that the company's orders allow
state they:
suppliers to comply with the company's ESG requirements.
This option guarantees that the company is continuously
• Do not use goods or services in the
reviewing its purchasing practices to avoid potential conflicts
with its ESG strategy.
• Do not re-
customers, and
Exclusion of suppliers that cannot achieve minimum ESG
• Do not utilize goods or services as capital goods
requirements within a set timeframe: Companies should set
(e.g.,
minimum requirements that suppliers must comply with to
operations.
access tenders or be selected for contract awarding. The best
practice for companies is interacting with those fundamental
Industry-specific special cases:
suppliers which do not meet these requirements and
providing development opportunities with the objective of
REI Equity Real Estate Investment Trust (REITs): companies
improving their performance and becoming eligible. This
opportunity should have a clear timeframe set, after which
as the main activity of the business in question '0.1
suppliers that are not able to meet expectations should be
me
question.
eligible.
REM Real Estate Management & Development: companies

Preference of suppliers with a better ESG profile by applying
a minimum weight to ESG criteria: Supplier preference
business in question '0.1 Denominator Area', should mark
rationale can vary for different industries, locations, and
business models. Among well-known dimensions such as
price, delivery times, and quality, ESG performance should
OIE - Energy Equipment & Services Industry: Services
also be considered. Most advanced companies incorporate
Companies (consultancy or seismic surveying), should mark
selection methodologies a specific weight for ESG

dimensions, which guarantees that sustainability is
embedded into supplier selection and contract awarding. Standards & Frameworks
CSRD - G1-2 15a AR 2-AR 3, G1-2 15b AR 2-AR 3
ESG Disclosure Standards (China) - G.3.3.2 Integrating ESG
on the Supplier ESG Programs: It is crucial for companies to into business management
set up training for buyers and/or relevant internal SASB - FB-RN-430a.3
stakeholders in their roles and on how their day-to-day UNGP - A2.4, C4
actions and decisions are fundamental to reach the
training is not accepted for this option.
89 / 252
Supplier Screening
Assessment Focus
Question Rationale from the ESG and business operation perspective. Once a
company has identified significant suppliers, it can focus
Companies not only outsource production, services, and
supplier monitoring and development efforts on those
business processes but responsibilities, risks, and
suppliers with the highest risk for negative impacts and
opportunities as well. On one hand, outsourcing generally
greatest business relevance (this aspect is examined in
tends to increase a company's flexibility, but on the other
subsequent questions). Therefore, this question seeks to
hand, supply chain risks might become less apparent, new
assess if companies have a systematic approach to screening
dependencies may arise, and the identification, monitoring,
suppliers in order to identify potential sustainability risks in
and management of risks and opportunities in the supply
their supply chain. Companies that are able to properly
chain may become more difficult.
identify significant suppliers will also be better positioned to
prioritize their risk management measures and proactively
An important first step in supply chain management is to try
to understand supply chain risks and dependencies
Question Layout
Does the company conduct supplier screening to systematically identify significant suppliers and is this information available
publicly?
□ Yes, the company conducts supplier screening to identify significant suppliers. Please indicate where this information is
Aspects of suppliers screening

Please indicate which of the following aspects are considered in your screening process for significant suppliers.
□ Environmental
□ Social
□ Governance
□ Business relevance
Methodology for suppliers screening

Please indicate which of the following risks are considered in your screening process for significant suppliers.
□ Country-specific risk
□ Sector-specific risk
□ Commodity-specific risk
with the support of or through external specialists. Screening

can be considered the initial step to identify potential
Supplier screening: Supplier screening is systematic desk sustainability risks in the supply chain and it is then followed
by assessing suppliers. At this stage, the company is not
business relevance, considering available data sources such likely to be engaging directly with the supplier in order to
as country, sector, or commodity ESG risks, spending, screen them.
business relevance, etc. Methodology development and
screening process can be realized by the company itself, or
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Significant suppliers: Significant suppliers are suppliers that of evidence (see Supplier Assessment and Development
are identified as having substantial risks of negative ESG question). We will only accept the usage of the Ecovadis if it is
impacts or significant business relevance to the company or a specified that risk maps or risk screening tools provided were
combination of both. The portfolio of significant suppliers used for this purpose (e.g., Ecovadis IQ plus).
assessment and development program. Critical suppliers Supporting evidence:

identified are also accepted as significant suppliers, even
though in most cases only business relevance, and not ESG This question requires public evidence. Please indicate
where in your public reporting you report information
risk, is considered when identifying critical suppliers. about the selected options.
Environmental aspects: The risk for negative impacts related Not Applicable General Rule
to environmental topics, including but not limited to
greenhouse gas emissions, energy consumption, water Not Applicable for this question (beyond the industries
consumption, resource efficiency, pollution, waste, or detailed below) will only be accepted for special cases. In
biodiversity. such cases, the company must credibly explain via a
comprehensive company comment and/or public reporting
Social aspects: The risk for negative impacts related to social that it does not purchase goods or services for the purposes
topics, including but not limited to human rights and labor below. To be granted Not Applicable , the company must
rights such as child labor, forced labor, discrimination, state they:
freedom of association, right to collective bargaining, working
hours, remuneration, occupational health and safety, or the •
rights of local communities. production processes, and
• Do not re-
Governance aspects: The risk for negative impacts related to customers, and
governance topics, including but not limited to corruption, • Do not utilize goods or services as capital goods
bribery, conflicts of interest, or anti-competitive practices. (e.g.,
operations.
Business relevance: Business relevance considerations,
including but not limited to share of spend/volume and Industry-specific special cases:
substitutability.

Country-specific risk: Risk for negative environmental, social
and governance impacts related to a country's political, as the main activity of the business in question '0.1
social, economic, environmental or regulatory situation.
question.
Sector-specific risk: Risk for negative environmental, social,
and governance impacts related to a sector's distinct REM Real Estate Management & Development: companies
characteristics regarding labor situation, energy that have on
consumption, resource intensity, emissions, or pollution business in question '0.1 Denominator Area', should mark
potential (e.g., manufacturing, service provision, agriculture)
Commodity-specific risk: Risk for negative environmental, OIE - Energy Equipment & Services Industry: Services
social, and governance impacts related to a commodity's Companies (consultancy or seismic surveying), should mark
supply chain structure, labor situation, land-use and resource .
intensity, energy consumption, emissions, material toxicity,
or pollution potential (e.g., metals, fossil fuels, wood, soy,
cotton)
Data Requirements
This question requires a risk screening carried out by the
company or third party, therefore the indication of a self-
assessment conducted by the suppliers, or generally using
Ecovadis would not be accepted as the Ecovadis assessment
is collecting supplier policies, practices, and performance
and qualifies as a Supplier Desk Assessment with verification
91 / 252
CSRD - G1-2 15a AR 2-AR 3 IRIS+ - OI4739
ESG Disclosure Standards (China) - S.3.1.2 Supplier selection SASB - CG-TS-430a.2, FB-NB-430a.1, FB-RN-430a.3
and management UNGC Questionnaire - G6, G7
92 / 252
Supplier Assessment and Development
Assessment Focus
Question Rationale
chain risks might become less apparent, new dependencies
The purpose of this question is to assess if companies have a
may arise, and the identification, monitoring and
systematic approach to evaluating suppliers and their
management of risks and opportunities in the supply chain
subsequent development to meet company requirements.
may become more difficult. Supplier assessment and
This should be with an overall goal of a shared mindset
development measures to assess and improve individual
leading to improved and scalable impact in the supply chain.
suppliers' performance are usually implemented after the
Companies not only outsource production, services and
initial supplier screening, which aims at identifying supplier
business processes but responsibilities, risks and
risks through desk research.
opportunities as well. On one hand, outsourcing generally
tends to increase a company's flexibility, but on the other
This question is divided into two parts: what the supplier
hand, supply
assessment process includes and what the supplier
development process includes.
Question Layout
Does the company have a process for supplier assessment and development and is it available publicly?
□ Yes, the company has a supplier assessment and development process. Please indicate where this information is available
in public reporting or corporate website.
Supplier assessment
□ Yes, the company has a publicly available supplier assessment process in place which includes the following:
Please provide public supporting evidence:
□ Supplier desk assessments with systematic verification of evidence
□ Supplier on-site assessments carried out by purchasing company employees or contracted consultant (2nd party
assessment)
□ Supplier on-site assessments carried out by an independent accredited auditing body (3rd party assessment).
□ Supplier assessments (desk or on-site) are carried out using standards and methodologies of a recognized industry or
multi-stakeholder initiative. Please provide name/description:
□ Supplier corrective action/improvement plans
□ No, the company does not have a publicly available supplier assessment process in place.
Supplier Development
□ Yes, the company has a publicly available supplier development process in place which includes the following:
Please provide public supporting evidence:
□ Supplier information/trainings on company's supplier ESG program, process and requirements

□ Supplier access to ESG benchmarks against peers
□ Supplier support (remote/on-site) on implementation of corrective/improvement actions
□ In-depth technical support programs to build capacity and ESG performance in suppliers
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□ No, the company does not have a publicly available supplier development process in place.
Question-Specific Guidance & Definitions representatives, employees, and other stakeholders. Applied
Assessment process methodologies can consist of their own checklists or
standards and methodologies of a recognized industry or a
Supplier assessment process: A process in which suppliers multi-stakeholder initiative. On-site assessments can also
are evaluated to obtain information on their practices in order include virtual assessments or supplier employee surveys.
to measure and monitor their performance. The assessment
process can be carried out in order to reduce costs, mitigate Supplier assessments (desk or onsite) are carried out using
risks and drive improvement. The benefits of carrying out this standards and methodologies of a recognized industry or
process include increased performance visibility and aligning multi-stakeholder initiative. Desk or on-site assessments
customer and supplier business practices, and risk that are carried out following standards and methodologies of
mitigation. a recognized industry or multi-stakeholder initiatives such as
SMETA, Responsible Business Alliance, amfori BSCI,
Supplier desk assessments with systematic verification of Responsible Minerals Initiative, SAI Platform, or others.
evidence: This type of supplier assessment is realized by, or
on behalf of, the purchasing company. It generally takes the Supplier corrective action plans: A corrective action plan
form of a questionnaire where suppliers are requested to (CAP) is an important quality management tool for any
provide information and supporting evidence on their ESG business or supplier. A corrective action plan is a method of
policies, practices, performance, and public disclosures. This documenting non-compliance issues, identifying their root
information is then reviewed, verified, and analyzed, resulting causes, and capturing measurable, achievable solutions and
in an appraisal of the supplier's ESG performance, possibly realistic deadlines.
with a score. This process is considered to be systematic
verification because established specifications and Development process
requirements are met. Supplier desk assessments are more
company-specific than supplier screenings (see question Supplier information/training: Providing the supplier with
supplier screening) as they assess the information provided inf
by the supplier and are usually realized in a subsequent stage supplier ESG program. This can be accomplished through
of the supplier assessment process. Desk assessments do various mediums. The content can range from specific inputs
not include onsite assessments of the supplier. Purchasing on one topic, inputs on multiple ESG topics and best
companies can implement their own supplier desk practices, to information on the co
assessment tools or can use tools of external providers, such development process.
as RBA Risk-based SAQ, Ecovadis, Together for
Sustainability, Achilles, Higg Facility Environmental Module Supplier access to ESG benchmarks: This is where suppliers
(with remote verification), etc. are provided with access to information on how other
suppliers are performing. This can include performance
2nd party supplier on-site assessments are carried out by information on specific areas or case studies on how other
employees of the purchasing company or by contracted suppliers achieved that level of performance.
consultants. These auditors do not need to be approved or
accredited by the standard-setting organization or by an Supplier support (remote/onsite) on implementation of
accreditation body. corrective/improvement actions: The company provides
guidance and support on the implementation of corrective
3rd party supplier onsite assessments are carried out by and improvement actions. This can happen remotely or
independent 3rd party auditing organizations that are through supplier on-site visits.
approved/accredited by the standard-setting organization
(e.g., Amfori BSCI, Responsible Business Alliance, Higg In-depth technical support programs to build capacity and
Facility Environmental Module) or by an accreditation body ESG performance in suppliers: Comprehensive capacity
along the requirements of ISO/IEC 17021 Conformity building programs to systematically improve supplier
assessment Requirements for bodies providing audit and practices and performance on specific ESG topics (e.g.,
certification of management systems (e.g., SA8000, ISO energy efficiency, chemical management, health & safety
standards). management, working hours reduction) through training,
baseline assessments, collaborative system development,
Supplier on-site assessments are on-site supplier visits by an and progress measurement. Capacity-building is defined as
auditor to assess the supplier's ESG operations, policies, the process of developing and strengthening the knowledge,
systems, and performance, usually involving document and skills, instincts, abilities, processes, and resources that
record reviews, site tours, as well as interviews with company organizations need to survive, adapt, and thrive in a fast-
94 / 252
changing world. Such programs go beyond corrective action comprehensive company comment and/or public reporting
support and usually take 6+ months to implement. These that it does not purchase goods or services for the purposes
technical support programs are long-term and sustained over below. To be granted Not Applicable , the company must
time with the aim of improving ESG performance rather than state they:
solely implementing action plans. •
• Do not re-
Data Requirements customers, and
If a company selects that yes, they have an assessment • Do not utilize goods or services as capital goods
and/or development process but does not select any of the (e.g.,
subsequent options then the answer will not be accepted. operations.
We expect publicly available information for this question. It Industry-specific special cases:
is possible that a company only publicly reports on its

assessment process and not on the development process REI Equity Real Estate Investment Trust (REITs): companies
therefore the company has the option to provide public

reporting for one part and select that they do not carry out the as the main activity of the business in question '0.1
other option.
question.
• The document(s) you attach will be used to verify REM Real Estate Management & Development: companies
the qualitative part of your response. Any

qualitative response that cannot be verified in the business in question '0.1 Denominator Area', should mark
attached document(s) or via the information

provided in the related question text field (if
available) will not be accepted. OIE - Energy Equipment & Services Industry: Services
• Supporting documents need to be available in the Companies (consultancy or seismic surveying), should mark
public domain.
• Information related to the assessment and
development process can be in separate documents
Standards & framework
for example, a responsible sourcing strategy and a
sustainability report. Scattered information that CSRD - G1-2 15a AR 2-AR 3, S2-4 33b
does not clearly relate will not be accepted. ESG Disclosure Standards (China) - S.3.1.2 Supplier selection
and management
Not Applicable General Rule GRI Disclosure - 308-2, 414-2
IAST APAC - Core Modern Slavery Metrics
Not Applicable for this question (beyond the industries SASB - CG-AA-430b.1, FB-AG-430a.2, FB-PF-430a.2, FB-RN-
detailed below) will only be accepted for special cases. In 430a.3
such cases, the company must credibly explain via a UNGP - C4, C5
95 / 252
KPIs for Supplier Screening
Assessment Focus
Question Rationale
understand if companies are capturing the number of
The purpose of this question is for companies to disclose the
different suppliers they have, whether they are categorized
results of the supplier screening process. It is important to
into significant suppliers, and whether new suppliers are
monitor the coverage and results of a supplier screening
screened for ESG risks. This question forms the basis for the
program to ensure suppliers are being screened and
categorized appropriately and that risks are being managed.
This question seeks to
Question Layout
Does your company monitor and report on coverage and progress of your supplier screening program?
□ Yes, we monitor and report on coverage and progress of your supplier screening program
Supplier Screening, FY 2023
1.1 Total number of Tier-1 suppliers
1.2 Total number of significant suppliers in Tier-1
1.3 % of total spend on significant suppliers in Tier-1
1.4 Total number of significant suppliers in non Tier-1
1.5 Total number of significant suppliers (Tier-1 and non Tier-1)
PUBLIC REPORTING
□ Our data is publicly available. Please provide supporting evidence or web link.
THIRD-PARTY VERIFICATION
□ Our data has been third-party verified in the most recent financial year reported. Please provide supporting evidence.
Question-Specific Guidance & Definitions multiple counts of suppliers if they were screened more than
Supplier screening: once during the reporting period).
risk for negative ESG impacts and their business relevance,

considering available data sources such as country, sector, or Significant suppliers: Significant suppliers are suppliers that
commodity ESG risks, spending, business relevance, etc. are identified as having substantial risks of negative ESG
Methodology development and screening process can be impacts or significant business relevance to the company or a
realized by the company itself, or with the support of or combination of both. The portfolio of significant suppliers
through external specialists. should be the key audience of a co

assessment and development program. Critical suppliers
Suppliers are only counted once within the fiscal year. When identified are also accepted as significant suppliers, even
providing data, please note that these are unique significant though in most cases only business relevance, and not ESG
suppliers screened during the reporting period (not the risk, is considered when identifying critical suppliers
number of screenings realized, i.e., no

Tier 1 suppliers: This refers to suppliers that directly supply
goods, materials or services (including intellectual property
96 / 252
(IP) and patents) to the company. If the company does not
specify, we will assume it is Tier 1. Not Applicable for this question (beyond the industries
detailed below) will only be accepted for special cases. In
Non-tier 1 suppliers: This refers to suppliers that provide such cases, the company must credibly explain via a
their products and services through Tier 1 suppliers to the comprehensive company comment and/or public reporting
company. Non-tier 1 suppliers are located beyond Tier 1 that it does not purchase goods or services for the purposes
suppliers, e.g., on Tier 2, 3 or n-level of a company's supply below. To be granted Not Applicable , the company must
chain. state they:
•
Data Requirements
Public Reporting • Do not re-
• In order to accept public reporting for the screening customers, and
process, disclosure is needed for • Do not utilize goods or services as capital goods
of significant suppliers in Tier- 1. 3. Percentage (e.g.,
of total spend on significant suppliers in Tier-1" and operations.
1.4 Total number of significant suppliers in non
Tier-1" for the last fiscal year. Industry-specific special cases:
Third Party Verification REI Equity Real Estate Investment Trust (REITs): companies
• To accept third party verification, data must be
verified for the most recent financial year by an as the main activity of the business in question '0.1
appropriate verification or auditing firm.
Government verification is not considered relevant question.
No significant suppliers identified REM Real Estate Management & Development: companies
business in question '0.1 Denominator Area', should mark

(1.2) and Total number of significant suppliers in non Tier-1
(1.4) are equal to zero, this is only acceptable if
• The company publicly reports on an acceptable OIE - Energy Equipment & Services Industry: Services
systematic supplier screening approach to identify Companies (consultancy or seismic surveying), should mark
significant suppliers in the Supplier Screening
question and;
• The company publicly reports that it identified zero
significant suppliers as having substantial risks of
negative ESG impacts or significant business CSRD - G1-2 15a AR 2-AR 3
relevance to the company or a combination of both. ESG Disclosure Standards (China) - S.3.1.1 Number and
Please note that answering 0 in this question will affect the distribution of suppliers
successive questions in this criterion. GRI Disclosure - 2-5, 2-6
IRIS+ - PI3016, PI9566
Not Applicable General Rule SASB - CG-AA-000.A, CG-AA-430a.1, CG-AA-430b.1
97 / 252
KPIs for Supplier Assessment and/or Development
Assessment Focus
Question Rationale building capacity within its supply chain. This question seeks
to understand if companies are capturing the number of
The purpose of this question is for companies to disclose the
different suppliers they have, how many are assessed, and
results of the supplier screening process and subsequent
how many out of those have been identified as having
assessment and/or development processes. It is important to
significant actual/potential negative impacts. From this, the
monitor the coverage and progress of a supplier assessment
purpose is to ascertain how many of those suppliers are
and/or development program to ensure risks are being
supported to improve their actions and in what ways.
managed and that the company is acting responsibly by
Question Layout
Does your company monitor and report on the coverage and progress of your supplier assessment and/or development program?
Please report the number of unique suppliers, which were identified as significant in the supplier screening process. These are unique
significant suppliers assessed during the reporting period (not number of assessments realized, i.e. no multiple count of suppliers if
they were assessed more than once during the reporting period).
□ Yes, our company monitors and reports on the coverage and progress of our supplier assessment and/or development
program. It includes the following:
□ Coverage and progress of our supplier assessment program
Supplier Assessment FY 2023 Target for FY 2023
1.1 Total number of suppliers assessed via desk

assessments/on-site assessments
1.2 % of unique significant suppliers assessed
1.3 Number of suppliers assessed with substantial

actual/potential negative impacts
1.4 % of suppliers with substantial actual/potential negative
impacts with agreed corrective action/improvement plan
1.5 Number of suppliers with substantial actual/potential
negative impacts that were terminated
□ Coverage and progress of suppliers with corrective action plans
Corrective action plan support FY 2023 Target for FY 2023
2.1 Total number of suppliers supported

in corrective action plan implementation
2.2. % of suppliers assessed with

substantial actual/potential negative
impacts supported in corrective action
plan implementation
□ Coverage and progress of suppliers in capacity building programs
98 / 252
Capacity building programs FY 2023 Target for FY 2023
3.1 Total number of suppliers in capacity building programs
3.2 % of unique significant suppliers in capacity building

programs
PUBLIC REPORTING
Question-Specific Guidance & Definitions evaluate the supplier and ensure a thorough review and
appraisal of the information provided and that allows them to
Supplier screening:
share the assessment results with other companies who
risk for negative ESG impacts and their business relevance,
might want to procure from. This could be RBA Risk-based
considering available data sources such as country, sector, or
SAQ, Ecovadis, Together for Sustainability, Achilles, Higg
commodity ESG risks, spending, business relevance, etc.
Facility Environmental Module (with remote verification), etc.
Methodology development and screening process can be
realized by the company itself, or with the support of or
2nd party supplier on-site assessments are carried out by
through external specialists.
employees of the purchasing company or by contracted
consultants. These auditors do not need to be approved or
Unique Significant suppliers: Suppliers that are identified as
accredited by the standard-setting organization or by an
having substantial risks of negative ESG impacts or
accreditation body.
significant business relevance to the company or a
combination of both. The portfolio of suppliers with
3rd party supplier on-site assessments are carried out by
sustainability priority should be the key audience of a
independent 3rd party auditing organizations that are
approved/accredited by the standard-setting organization
program. Critical suppliers identified are also accepted as
(e.g., amfori BSCI, Responsible Business Alliance, Higg
significant suppliers, even though in most cases only
Facility Environmental Module) or by an accreditation body
business relevance, and not ESG risk, is considered when
along the requirements of ISO/IEC 17021 Conformity
identifying critical suppliers.
assessment Requirements for bodies providing audit and
In this question, the company should refer to their unique
certification of management systems (e.g., SA8000, ISO
significant suppliers.
standards).
Desk assessments: This type of supplier assessment is

Supplier on-site assessments are on-site supplier visits by an
realized by, or on behalf of the purchasing company. It
auditor to assess the supplier's ESG operations, policies,
generally takes the form of a questionnaire where suppliers
systems, and performance, usually involving document and
are requested to provide information and supporting evidence
record reviews, site tours as well as interviews with company
on their ESG policies, practices, performance, and public
representatives, employees, and other stakeholders. Applied
disclosures. This information is then reviewed, verified, and
methodologies can consist of their own checklists or
analyzed, resulting in an appraisal of the supplier's ESG
standards and methodologies of a recognized industry or
performance, possibly with a score. This process is
multi-stakeholder initiative. On-site assessments can also
considered to be systematic verification because established
include virtual assessments or supplier employee surveys.
specifications and requirements are met. Supplier desk
assessments are more elaborate than supplier screenings
Supplier assessments (desk or onsite) are carried out using
(see question supplier screening) as they assess the
standards and methodologies of a recognized industry or
information provided by the supplier and are usually realized
multi-stakeholder initiative: Desk or on-site assessments
in a subsequent stage of the supplier assessment process.
that are carried out following standards and methodologies of
Desk assessments do not include onsite assessments of the
a recognized industry or multi-stakeholder initiatives such as
supplier. Purchasing companies can implement their own
SMETA, Responsible Business Alliance, amfori BSCI,
supplier desk assessment tools or can use tools of external
Responsible Minerals Initiative, SAI Platform, or others.
providers.
Substantial actual/potential negative impacts: In the GRI

For supplier desk assessments companies can use a third-
Standards, unless otherwise stat
party tool/methodology/online system in their assessment to
99 / 252
effect an organization has on the economy, the environment, • The supporting documents do not need to be
and/or society, which in turn can indicate its contribution available in the public domain however the company
(positive or negative) to sustainable development. Negative will not receive points for public reporting.
impacts include those that are either caused or contributed • We expect the data provided to be related to the
to by an organization, or that are directly linked to its number of unique significant suppliers as shown in
activities, products, or services by its relationship with a the question statement.
supplier. Actual impacts are those that have happened. •
Potential impacts are those which may occur and where
actions can be taken by the company to prevent, mitigate, or maximally
remediate the impacts; Substantial can be defined as a with susbtantial actual/potential negative
critical or major non-compliance with minimum requirements Essentially, the number provided in 2.1
leading to severe damage to the environment or people's cannot exceed the number in 1.3.
physical or psychological integrity or to the systematic failure
of the supplier to protect people or the environment from Public reporting
harm. In order to accept public reporting for KPIs for Assessment
and Development, the company needs to publicly disclose
Supplier corrective action plan: A corrective action plan (CAP) data on at least one of the following metrics:
is an important quality management tool for any business or • S
supplier. A CAP is a method of documenting non-compliance
issues, identifying their root causes, and capturing •
measurable, achievable solutions and realistic deadlines. suppliers supported in corrective action plan
This refers to suppliers that are in the process of
implementing their CAP. •
of suppliers in capacity buil
Supplier support (remote/onsite) on implementation of • If the company reports data but it is not available in
corrective action plans: The company provides guidance and the public domain, no points for public reporting will
support on the implementation of corrective and be awarded.
improvement actions. This can happen remotely or by visiting
the supplier. Third party verification
Third party verification is accepted if at least one of the
Capacity building programs: Comprehensive capacity metrics required for public reporting is verified by a third-
building programs to systematically improve supplier party. Data must be verified for the most recent financial year
practices and performance on specific ESG topics (e.g., by an appropriate verification or auditing firm. Government
energy efficiency, chemical management, health & safety verification is not considered relevant.
management, working hours reduction) through training,
baseline assessments, collaborative system development, Not Applicable General Rule
and progress measurement. Capacity-building is defined as Not Applicable for this question (beyond the industries
the process of developing and strengthening the knowledge, detailed below) will only be accepted for special cases. In
skills, instincts, abilities, processes, and resources that such cases, the company must credibly explain via a
organizations need to survive, adapt, and thrive in a fast- comprehensive company comment and/or public reporting
changing world. Such programs go beyond corrective action that it does not purchase goods or services for the purposes
support and usually take 6+ months to implement. These below. To be granted Not Applicable , the company must
capacity-building programs are long-term and sustained over state they:
time with the aim of improving ESG performance rather than
solely implementing action plans. •
• Do not re-
Data Requirements customers, and
• Quantitative figures provided in the response do not • Do not utilize goods or services as capital goods
need supporting evidence. You may still provide a (e.g.,
reference using the reference clip. This could operations.

approaches to data aggregation used to compile the Industry-specific special cases:
provided quantitative information.

100 / 252
as the main activity of the business in question '0.1

question.
CSRD - ESRS 2 MDR-T 80j AR 24 - AR 26, G1-2 15a AR 2-AR 3
REM Real Estate Management & Development: companies ESG Disclosure Standards (China) - S.3.2.2 Significant risks
that have on and impacts
business in question '0.1 Denominator Area', should mark GRI Disclosure - 2-5, 308-2, 414-2
SASB - CG-AA-430b.2, CG-TS-430a.2, FB-AB-430a.1, FB-AG-
430a.2, FB-FR-430a.3, FB-NB-430a.1, TC-ES-320a.2, TC-ES-
OIE - Energy Equipment & Services Industry: Services 320a.3, TC-HW-430a.1, TC-HW-430a.2
Companies (consultancy or seismic surveying), should mark UNGP - C5
101 / 252
Tax Strategy
Tax competition between tax territories (countries or regions negatively impacted. This could result in approval delays or
within countries) has left room for companies to optimize rejection of expansion projects or, in the worst cases,
their tax spending. While tax optimization has a positive companies risk losing their license to operate. Third, earnings
impact on profitability and hence company value, a too- might be impacted if the tax authorities decide to change tax
aggressive tax strategy might not be sustainable in the mid- regulation which leads to direct financial risks. Finally,
to long-term and adds some risk to long-term profits. First, economic development risk arises if governments receive
there is a reputational risk because of increased public and inadequate tax receipts for funding local infrastructure or
regulatory scrutiny which could result in lower brand value. education.
Second, the relationship with the host country may be
Tax Strategy and Governance
Assessment Focus
Question Rationale
Tax avoidance strategies are usually set up in a legally sound
against which practices and disclosures can be compared. An
intention to comply with all tax laws and regulations in its effective policy should be overseen by the board of directors,
countries of operation are not sufficient. Every company created in conjunction with relevant senior management, and
should be able to give a coherent justification of their regularly reviewed to ensure emerging risks are addressed.
approach to key tax issues such as the use of tax
minimization techniques in line with their approach to other This question seeks to determine if there is a group-wide tax
CSR issues. policy or strategy available in the public domain that
addresses sensitive or high-risk tax issues in a clear and
The adoption of a formal tax policy serves to guide company sustainable way.
practices and provide investors, regulators and other external
Question Layout
Does the company have a policy on tax strategy and governance at a group level and is it available publicly?
□ Yes, the company has a group-wide policy on tax strategy and governance. Please indicate where this information is
□ A commitment to compliance with the spirit as well as the letter of the tax laws and regulations in the countries in
which the company operates
□ A commitment not to transfer value created to low tax jurisdictions
□ A commitment not to use tax structures without commercial substance
□ inciple
□ A commitment not to use secrecy jurisdictions or so-
□ An approval process of the tax policy by the board of directors
Question-Specific Guidance & Definitions undermine tax law and public policy and it is frequently found
to be unlawful. Tax avoidance can be within the letter, but not
Tax avoidance: Tax avoidance is an abuse of the tax system, a
the spirit, of the law. (Source: TaxWatch)
deliberate attempt to get out of an obligation to pay tax by
The spirit of the tax laws: This refers to the intention of the
entering into a set of artificial financial arrangements which
policy maker who wrote the respective law.
have little or no commercial purpose other than the reduction
of a tax bill. Tax avoidance is unethical in that it seeks to
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The letter of the law: This refers to the literal interpretation of Data Requirements
the law only.
While many companies have group-wide tax accounting
policies with clearly defined roles and responsibilities within
Low tax jurisdiction: For the purpose of this question, low tax
the organization in place, we specifically look for taxation
jurisdiction refers to any jurisdiction with significantly lower
policies that address issues such as responsible taxation,
tax rates than other jurisdictions in which the company
transparency, transfer pricing, etc., going beyond minimum
operates.
legal tax disclosure requirements.
This valuation principle is

commonly applied to commercial and financial transactions
between related companies. It says that transactions should
be valued as if they had been carried out between unrelated
parties, each acting in their own best interest.
integrated report, company publications, separate fuel
Tax havens: (Offshore) countries or jurisdictions offering little
efficiency strategy document) or corporate website.
or no tax liability. Tax havens may only share limited or no
financial information with foreign tax authorities and may not
require businesses to operate out their country to receive tax
benefits.
The board of directors: For the purpose of this question, this Standards & frameworks
can refer to the board of directors, its subcommittees, or a GRI Disclosure - 207-1
single named director. The tax policy must be approved or SFDR Principal Adverse Impacts - Governance
signed by the respective board representative(s), and/or
clearly state their involvement in the creation of the tax
policy. General statements regarding the responsibilities of
the board of directors or regular reporting to the board are not
enough.
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Tax Reporting
Assessment Focus
Question Rationale
Leading companies have realized that public reporting on active companies can steer and facilitate the discussion
their revenues, operating profits and tax on a country-by- about their tax contributions with all their stakeholders by
country basis helps build trust in their corporation and explaining the reasons behind the difference in their
complements the reporting on their broader economic reporting.
contribution. In combination with key information about the
names and tax residence of all constituent entities, the main In this question, we aim to identify to what extent companies
activities by tax jurisdiction as well as the average number of report key information about their tax contributions in all tax
jurisdictions where the entities included in their
profile and potential exposure to tax risks. If tax payments
differ from the expected rates in a given jurisdiction, pro- resident for tax purposes.
Question Layout
Does the company publicly report on key business, financial and tax information for each tax jurisdiction in which they operate and is
it available publicly?
□ Yes, the company reports on key business, financial and tax information. Please indicate where this information is available
□ Names of all the resident entities
□ Primary activities
□ Number of employees
□ Revenue
□ Profit (Loss) before tax
□ Income tax accrued (current year)
□ Income tax paid
Question-Specific Guidance & Definitions profit and loss, such as the income statement or profit and
loss statement, should be reported as revenues.
A constituent entity is a separate business unit, or
subsidiary, of a multi-national enterprise group that is
Profit (Loss) before tax: Also referred to as pre-tax profit
included in the consolidated group for financial reporting
(loss), pre-tax income or earnings before tax (EBT). We also
purposes. This includes a permanent establishment if a
accept operating profit, earnings before interest and tax
separate income statement is prepared for regulatory,
(EBIT).
financial, internal management or tax purposes.
Income Tax Accrued (Current year) is the amount of accrued

A description of the primary activities by jurisdiction can be
current tax expense recorded on taxable profits or losses for
in the form of a short statement regarding the nature of the
the reporting fiscal year of all constituent entities resident for
trade in the respective location (e.g., Sales, Marketing or
tax purposes in the relevant tax jurisdiction irrespective
Distribution, Manufacturing or Production, Purchasing or
of whether or not the tax has been paid (e.g., based on a
Procurement, R&D, Holding or Managing Intellectual
preliminary tax assessment). The current tax expense only
Property, etc.).
reflects operations in the current year and does not include
deferred taxes or provisions for uncertain tax liabilities.
Revenues: All revenues, (extraordinary) gains and income, or
However, for the purpose of this question, country-by country
other inflows shown in the financial statement prepared in
accordance with the applicable accounting rules relating to
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reporting on income tax expense, corporate income tax or • Income tax accrued (current year)
current tax provisions is also accepted. • Income tax paid (cash basis)
Income Tax Paid (on Cash Basis) is the amount of corporate To receive credit for public reporting on the non-financial
income taxes actually paid during the reporting fiscal year, metrics (i.e., names of constituent entities, the primary
which should thus include not only advanced payments activities, and the number of employees), companies are
expected to clearly state that the information includes all
payments fulfilling the e.g., constituent entities of the organization. Additionally, in order
payment of the unpaid balance of corporate income tax for any of these non-financial metrics to be accepted, at least
accrued in relation to the previous year(s), including one of the financial metrics mentioned above has to be
payments related to reassessments of previous years), accepted as well.
regardless of whether those taxes have been paid under
protest. Consolidated taxes paid that include other items In the case at least 90% of the respective metric (e.g.,
such as value-added tax, social security taxes, regional or revenues) comes from one country(e.g.,
industry-specific taxes are not accepted. remaining amount of the respective metric has to be
summarized as "Other", "Foreign", "International" or similar.
The amount of Income Tax Accrued (Current Year) and Income The disclosed metrics must fully reconcile with the
Tax Paid (on Cash Basis) should be reported independently. corresponding figures in the consolidated income statement.
The Number of Employees should reflect the average number If there is more than one constituent entity in a jurisdiction,
of FTEs (full-time equivalents) during the reporting fiscal the numbers can be reported on an aggregate basis at a
year, or a similar number, provided that it is applied jurisdictional level. Accordingly, data should be reported on
consistently across the jurisdictions. Reasonable rounding is an aggregated basis, regardless of whether the transactions
permissible, if it does not materially distort the relative occurred cross-border or within the jurisdiction, or between
distribution of employees across tax jurisdictions. related parties or unrelated parties. If possible, however,
companies should report consolidated figures if consolidated
data can be reported for each jurisdiction. Companies should
Data Requirements state clearly if the data is reported on an aggregated or
Please note: The tax data disclosed should fully reconcile consolidated basis.
with the corresponding information in the consolidated

income statement. References
OECD / G20: Base Erosion and Profit Shifting Action 13
To receive credit for comprehensive country-by-country
reporting, we expect the countries reported on to cover at
least 90% of the respective financial metric. This means that Standards & frameworks
in order to receive credit for all boxes, we expect distinct
GISD-Country by country tax reporting
disclosure for each of the metrics below, disclosing at least
90% of the respective consolidated total values in the income
IRIS+ - OD6855
statement:
WEF Metrics - Total tax paid by country for significant
• Revenues
locations
• Profit (loss) before tax
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Effective Tax rate
Assessment Focus
Question Rationale
companies and countries that it believes have illegal
may be unsustainable in a global context, based on the agreements, for example, those in violation of state aid rules.
reported tax rate and cash tax rate for the last two years. More recently, the European Commission announced in
Governments around the world have been increasingly critical March 2018 that it has proposed: 1) to reform corporate tax
of base erosion and profit shifting (BEPS) which enables tax rules so that profits are registered and taxed where
avoidance through the exploitation of gaps and mismatches businesses have significant interaction with users through
in tax rules, allowing companies to shift profits to low or no- digital channels; and 2) an interim tax on certain revenues
tax jurisdictions. Some of the resulting corporate structures from digital activities. We expect this type of cooperation and
and agreements with local governments may be drawn up in a regulation to continue, targeting companies and countries
legally sound way, while others may not, even if they may with low tax rates, and removing the loopholes and
currently appear so. Long term financial risks can also agreements that allow companies to operate with relatively
develop from arrangements that are later determined to be low rates in the long term. In addition to the regulatory
eroding the tax base of other countries or provide an unfair developments listed above, consumers (and voters) are
subsidy. These arrangements may be deemed illegal, and becoming increasingly aware of companies that pursue
fines and penalties imposed, or new regulations may be aggressive tax strategies as recent controversies around
implemented which raise the tax obligation of companies. At several major multinational companies have shown.
the same time regulatory bodies are increasing the Therefore, both reputationally and politically there are
enforcement of existing rules. growing risks of a mean reversion or even financial penalties
associated with these practices.
The OECD commenced the BEPS project in 2015 to address
these issues and the EU has been aggressive in targeting
Question Layout
Please complete the following table related to your reported tax rate (income statement) and cash tax rate (cash flow statement) for
the last two years. Please indicate where this information is available in your financial reporting.
Additionally, please select (if necessary) why the reported tax rate and/or the cash tax rate might be lower than expected. Please see
the information button for additional information.
□ Currency:
Financial Reporting FY 2022 FY 2023 Calculated Average Rate

Earnings before Tax
Reported Taxes
Cumulative acceptable
adjustments* (see below)
Effective Tax Rate (in %) Automatic calculation of your
Reported Taxes in the two-
year period (with
adjustments) divided by your
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Earnings before Tax in the
two-year period.
Cash Taxes Paid
Cash Tax Rate (in %) Automatic calculation of your
Cash Taxes Paid in the two-
year period divided by your
Earnings before Tax in the
two-year period.
*Note: If the calculated average tax rate and/or cash tax rate is lower than the industry group averages shared via the information
text, please specify the reason why, indicate the tax amount per item and provide explanations in the table below. Please also
indicate where this information is available in your public reporting or corporate website.
If the aspect reduced your tax burden (tax benefit), please indicate the impact as a negative number, however if the
aspect increased your tax burden (tax expense), please indicate the impact as a positive number. On the basis of the numbers
inputted, you will see an autocalculation of the rate above: please double-check that figure to ensure you have reported these
aspects with the correct sign.
Non-Listed companies may provide internal documents and/or links public reports or corporate websites.
Reason Tax Impact FY 2022 Tax Impact FY 2023 Explanation

□ Group-wide net
operating losses (in
FY2022 or FY2023)
□ Single jurisdiction tax

code (maximum 10%
sales abroad and
domestic corporate
income tax rate below
the posted industry
group average)
□ Non-recurring (one
time) operating losses
in own operations
□ Net operating losses

from prior periods
and/or acquired
companies
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□ Timing - net deferred
tax assets/liabilities
and major issues
outside of the two year
period reported
(including accounting
adjustments for prior
reporting periods due
to major tax policy
changes)
should be added back to the reported or cash tax amounts
Question-Specific Guidance & Definitions actually reported, leading to the higher reported tax rate or
cash tax rate.
Tax rate: The percentage at which an individual or a
corporation is taxed. Group-wide net operating losses:
are a tax credit created when a company's expenses exceed
Reported taxes: The amount of taxes imposed on an its revenues, generating negative taxable income as
organization as this is reported on the income statement. computed for tax purposes. NOL can be used to offset
positive taxable income, reducing cash taxes payable. NOL
Cash taxes: The amount of taxes paid to governmental can be carried back 2 years to recover past taxes paid and
authorities as indicated in the cash flow statement of that forward 20 years to offset taxable income in future periods.
fiscal year. After 20 years, any remaining NOL expire and are no longer
• For example, for FY 2018 please provide all cash available for use. NOL carried forward are recorded on the
taxes paid during FY 2018, regardless of the period
the tax liability arose in. Source: Macabacus
Special note for companies subject to Zakat (Islamic tax) In the case a company has group-wide losses, there is no
Zakat is a tax on assets, therefore qualifies as a wealth tax, associated amount since there is no income.
not an income tax. In this question we focus on income tax
only. Therefore, Zakat should be excluded from the Non-recurring (one-time) losses in own operations: Non-
recurring (one-time) losses are irregular or infrequent losses
(e.g., write-off of a large investment, large settlement or fine)
If the company If the company operates in a single that would offset ongoing income generated.
jurisdiction, and only owes Zakat as taxes (and not income
Net operating losses from acquired companies: This option
both tables empty and provide explanations in the comment
box below. Please follow the same approach if the company assets are stepped-up for tax purposes, the target's net
operates in a single jurisdiction and reports on income tax operating losses (NOL) may generally be used immediately by
and zakat all combined (e.g., taxation and zakat). the acquirer to offset the gain on the actual or deemed asset
Macabacus
If the company does not operate in a single jurisdiction but
only reports on zakat and tax paid all combined, please leave Single jurisdiction tax code: (e.g., low domestic rate and
the cash tax paid box empty, and provide explanations in the maximum 10% sales abroad) Certain countries (e.g., Ireland)
comment box below. have a low tax rate for companies. Therefore, certain
countries will have a lower tax rate than the average in the
Tax amount: (in table explaining low taxes) if the taxes industry. If your company has more than 90% of sales
reported or paid in cash are lower than expected, companies domestically, this option can be ticked.
may have non-recurring items (e.g., net operating losses from
acquired companies, major write-offs that cause temporary Timing Issues outside of the two years period: This option
losses, tax settlement, etc.) that explain the low rate. The tax refers to an event that happened outside of the two years and
amount entered into the table is the amount of tax that was carried forward to the two last fiscal years. This could be
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losses from a company's own operations as described above, • Timing - issues outside of the two-year period
or due to a tax deal reached with the government. reported
The net change in valuation allowance can be accepted as

timing issue, provided the specific effect is clearly described provided in the confidential comment box) cannot be
in the public reporting. accepted as a supporting document for the second table,
unless it is verifiable in the public domain.
Data Requirements For all of the above:
Earnings before Tax (EBT) may also be known as Operating Listed and/or publicly owned companies are required to
Income before Tax or Profit before Tax and is often a unique provide links to public reports or corporate websites.
line item on the income statement. Two years of data are Non-listed companies should provide the following
required. evidence, depending on the type of company:
Family-owned companies and Privately owned companies are
To get a sense of whether your company's "calculated required to provide public reports, corporate websites, or
average tax rate and/or cash tax rate is lower than it might be internal documents.
expected by a stakeholder", please review the Average Cooperatives are required to provide public reports, corporate
Effective Tax Rate & Cash Tax Rate for each of the 24 GICS® websites, or internal documents.
Industry Groups, on page 108 of the CSA Handbook. State-owned companies are required to provide tax reporting
in the public domain as their key stakeholder is the general
In order to establish these industry group-specific public.
thresholds, we've updated our original, Bloomberg-based
research on the basis of the data we collected via the 2023
Corporate Sustainability Assessment. We took each References
company's average effective tax rate, and cash tax rate,
• Average Effective Tax Rate & Cash Tax Rate for each
respectively, and averaged over all the rates reported for that
of the 24 GICS® Industry Groups, please see
industry group worldwide.
the CSA Handbook, page 108
• Organization for Economic Co-operation and
Disclosure requirements Development (OECD) framework
Profit Shifting (BEPS)"
Disclosure of the following items for the last two fiscal years:
• Macabacus: http://macabacus.com/taxes/net-
• Earnings before tax
operating-loss
• Reported taxes
• Reported tax rate
• Cash taxes paid Standards & frameworks
• Cash tax rate
GISD-Payments to the government
IRIS+ - FP3673, FP5261
As stated in the question text: completion of the second table
WEF Metrics Total tax paid
of the question is not required, however, if it is completed, we
expect supporting evidence.
If any of the following items have been selected, then these

should be reported in the attached public evidence, as well as
the corresponding tax impact (if relevant for the selected
option):
• Group-wide net operating losses
• Non-recurring (one time) operating losses in own
operations
• Net operating losses from acquired companies
• Single jurisdiction tax code (e.g., low domestic rate
and maximum 10% sales abroad)
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Average Effective Tax Rate & Cash Tax Rate for each of the 24 GICS® Industry Groups
Average
Average Cash
GICS® Industry Groups Our Industries Effective Tax
Tax Rate
Rate
ATX Auto Components
Automobiles & Components 15.47% 20.90%
AUT Automobiles
DHP Household Durables

LEG Leisure Equipment & Products & Consumer
Consumer Durables & Apparel 21.23% 19.41%
Electronics
TEX Textiles, Apparel & Luxury Goods
CNO Casinos & Gaming
CSV Diversified Consumer Services

Consumer Services 18.60% 12.21%
REX Restaurants & Leisure Facilities
TRT Hotels, Resorts & Cruise Lines

IMS Interactive Media, Services & Home Entertainment
Media & Entertainment 16.83% 15.48%
PUB Media, Movies & Entertainment
Consumer Discretionary
RTS Retailing 23.39% 23.75%
Distribution & Retail
Consumer Staples Distribution
FDR Food & Staples Retailing 24.51% 24.72%
& Retail
BVG Beverages
Food, Beverage & Tobacco FOA Food Products 21.09% 22.78%
TOB Tobacco
Household & COS Personal Products

24.11% 33.29%
Personal Products HOU Household Products
COL Coal & Consumable Fuels
OGR Oil & Gas Refining & Marketing

Energy 15.06% 9.14%
OGX Oil & Gas Upstream & Integrated
OIE Energy Equipment & Services
Banks BNK Banks 21.29% 19.94%
Financial Services FBN Diversified Financial Services and Capital Markets 19.32% 20.95%
Insurance INS Insurance 14.97% 13.41%

Health Care Equipment &
MTC Health Care Equipment & Supplies 15.64% 16.38%
Services
BTC Biotechnology
Pharmaceuticals, Biotechnology
DRG Pharmaceuticals 7.89% 9.97%
& Life Sciences
LIF Life Sciences Tools & Services
Semiconductors &
SEM Semiconductors & Semiconductor Equipment 13.96% 13.82%
Semiconductor Equipment
SOF Software
Software & Services 14.13% 15.26%
TSV IT services
CMT Communications Equipment

Technology Hardware &
ITC Electronic Equipment, Instruments & Components 15.39% 15.09%
Equipment
THQ Computers & Peripherals and Office Electronics
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ALU Aluminum
CHM Chemicals
COM Construction Materials
Materials CTR Containers & Packaging 19.13% 20.65%

FRP Paper & Forest Products
MNX Metals & Mining
STL Steel
Real Estate Management &
REM Real Estate Management & Development 22.56% 15.47%
Development
Telecommunication Services TLS Telecommunication Services 17.67% 10.37%
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Information Security/Cybersecurity & System Availability
Due to the current trend of digitization, including but not Over the past decade, the number of information security
limited to cloud computing, online market places and breaches has been growing exponentially. The many incidents
payments etc., it is crucial that access to network, IT systems and their related costs have shown that information
and data is assured at all times. As a result, lower than security/cybersecurity has become a financially material
agreed upon system performance or service disruptions can issue which has to be managed diligently to protect corporate
result in higher costs and reputational risk for companies. The value. The costs of cybercrime are manifold and can impact
main risks stem from technical failure, human error, the company in different ways. Internal costs are operational
malicious attacks, weather events, natural disasters or costs and relate to dealing with the cybercrime and incidence
terrorist attacks. Managing such risks, including contingency prevention. External costs include the consequences of the
plans, is crucial to ensuring business continuity. The criterion cyber-attack such as the loss or theft of sensitive
focuses on how well companies are prepared to prevent IT information, operations' disruption, fines and penalties,
system failures and major information security/cybersecurity infrastructure damage or revenue losses due to loss of
incidents and if they can react appropriately in case of such customers. The criterion focuses on how well companies are
events. It also evaluates whether companies have prepared to prevent major information security/cybersecurity
experienced IT infrastructure / information security incidents and if they can react appropriately in case of an
/cybersecurity incidents in the past and if there was material attack. It also evaluates whether companies have
financial impact. experienced information security/cybersecurity incidents in
the past and what the financial consequences were.
IT Security/Cybersecurity Governance
Assessment Focus
Question Rationale
Due to the current trend of digitization, including but not costs and relate to dealing with cybercrime and incidence
limited to cloud computing, online marketplaces and prevention. External costs include the consequences of the
payments etc., it is crucial that access to network, IT systems cyber-attack such as the loss or theft of sensitive
and data is assured at all times. As a result, lower than information, operations' disruption, fines and penalties,
agreed upon system performance or service disruptions can infrastructure damage or revenue losses due to loss of
result in higher costs and reputational risk for companies. The customers. Thus, ensuring the security and resilience of
main risks stem from technical failure, human error, networks and information systems is critical.
malicious attacks, weather events, natural disasters or
terrorist attacks. Managing such risks, including contingency All boards should have the ability to understand cyber threats
plans, is crucial to ensuring business continuity. -
related issues according to the National Association of
Over the past decade, the number of information security Corporate Directors (NACD). However also senior executives,
breaches has grown exponentially with some attacks like CISO, CSO or CIO, must have the necessary leadership,
reaching unprecedented scale and the cyber threat landscape operational and strategic skills to understand and face the
continues to grow and evolve, abusing existing and new risk. A cyber-risk committee would have the role to encourage
technologies and exploiting vulnerable users. These incidents both the board and executives to give cyber-security issues a
and the related costs have shown that information high priority and to prioritize them with strong oversight.
security/cybersecurity has become a financially material
issue which must be diligently managed to protect corporate The question focuses on whether the company has the
value. The costs of cyberattack are manifold and can impact appropriate governance to prevent IT system failures and
the company in different ways. Internal costs are operational major information security / cybersecurity incidents.
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Question Layout
Are the board of directors and executive management engaged in the information security /cybersecurity strategy and review
process?
o Yes, we have a director on the board with relevant background in IT engaged on the cybersecurity strategy process and
□ Board Responsibility:
Please indicate the Board member who oversees Cybersecurity strategy together with his/her experience
.
Board Member
oversees cyber security strategy
□ Name of board member □ If publicly available, please indicate where this information can be
□ Relevant experience and previously held found in your public reporting or corporate website.
positions o Cybersecurity/information security committee
o Risk committee
o Audit committee
o Not known
□ Executive Management Responsibility
Please indicate which role or function within or reporting directly to the Executive Management team is responsible for overseeing
cybersecurity within the company.

□ If publicly available, please indicate where this information can be found in your public reporting or corporate
website.
▪ Chief Information Security Officer (CISO) / Chief Security Officer (CSO)
▪ Chief Technology Officer (CTO) / Chief Information Officer (CIO) or similar
▪ CEO / COO / CRO or similar with clear responsibility for IT security/ cybersecurity
▪ We do not have anyone who oversees cybersecurity in the executive management team
▪ Not known
Question-Specific Guidance & Definitions systems, computers, programs, and data from attack,
damage, or unauthorized access (according to SEC).
CISO: A chief information security officer (CISO) is the senior-
level executive in an organization responsible for establishing
Experience: Relevant experience could be past experience in
the implementation of IT, information security or
program to ensure information assets and technologies are
cybersecurity or operational responsibility for IT as a senior
well protected. As the highest-ranking cybersecurity
executive of a company. In addition for Board Member, non-
executive, the chief information security officer (CISO), or
technical experience as a senior executive of an IT company
alternatively the Chief Information Officer (CIO), is
(such as SVP Marketing, Sales etc.) is not valid. Academic
responsible for establishing and maintaining the enterprise
experience in IT is not considered relevant.
strategy and processes that protect information assets.
Information security: The protection of information and

CSO: A Chief Security Officer (CSO) is the senior-level
information systems from unauthorized access, use,
executive responsible for the physical security of a company,
disclosure, disruption, modification, or destruction in order to
provide confidentiality, integrity, and availability (according to
responsibility is to protect people, assets, technology, and
NIST).
infrastructure.
Cybersecurity: Cybersecurity is the body of technologies,

processes, and practices designed to protect networks,
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Information System: Applications, services, information For executive management responsibility, please indicate
technology assets, or other information handling components which role or function within or reporting directly to the
(according to ISO). Executive Management team is responsible for overseeing
cybersecurity within the company. The best practice is to
IT security: IT security is the process of implementing have a CISO or CSO as part of the Executive Management
measures and systems designed to securely protect and team or reporting directly to it. In case another function has
safeguard information utilizing various forms of technology. IT responsibility for IT security/cybersecurity and is part of or
security is thus considered a bit broader than cybersecurity. reporting directly to the Executive Management team, please
select the second or third option accordingly.
Important note: Throughout the whole criterion we always
refer to IT security, cybersecurity or information security
according to the definitions above. For the appraisal of the
"cybersecurity" equally.
Data Requirements
question: Additional credit will be granted for relevant
publicly available evidence covering:
• The board
which oversees cyber security strategy
• The role or function within or reporting directly to the
Executive Management team responsible for
overseeing cybersecurity within the company
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IT Security/ Cybersecurity Measures
Assessment Focus
Question Rationale
Due to the current trend of digitization, including but not incidents and the related costs have shown that information
limited to cloud computing, online marketplaces, and security/cybersecurity has become a financially material
payments, etc., it is crucial that access to networks, IT issue that must be diligently managed to protect corporate
systems and data is assured at all times. As a result, lower value. The costs of cyberattacks are manifold and can impact
than agreed upon system performance or service disruptions the company in different ways. Internal costs are operational
can result in higher costs and reputational risk for companies. costs and relate to dealing with cybercrime and incidence
The main risks stem from technical failure, human error, prevention. External costs include the consequences of the
malicious attacks, weather events, natural disasters or cyber-attack such as the loss or theft of sensitive
terrorist attacks. Managing such risks, including contingency information, operations' disruption, fines and penalties,
plans, is crucial to ensuring business continuity. infrastructure damage or revenue losses due to loss of
customers. Thus, ensuring the security and resilience of
Over the past decade, the number of information security networks and information systems is critical.
breaches has grown exponentially with some attacks
reaching unprecedented scales and the cyber threat The question assesses what security measures are in place to
landscape continues to grow and evolve, abusing existing and ensure employees are aware of threat issues and the
new technologies and exploiting vulnerable users. These importance of information security/cybersecurity.
Question Layout
Have you implemented policies and procedures for all employees in order to ensure that they are aware of threat issues and the
importance of information security/cybersecurity?
□ Yes, we have implemented policies and procedures for all employees
□ An information security/cybersecurity policy is internally available to all employees. Please provide the relevant document:
□ Information security/cybersecurity awareness training. Please explain and provide supporting evidence:
□ A clear escalation process which employees can follow in the event an employee notices something suspicious is in place.
Please explain and provide supporting evidence:
□ Information security/cybersecurity is part of the employee performance evaluation (e.g. disciplinary actions). Please explain
and provide supporting evidence:
Question-Specific Guidance & Definitions and data from attack, damage or unauthorized access
(according to SEC).
IT security: The process of implementing measures and
systems designed to securely protect and safeguard Information security: The protection of information and
information utilizing various forms of technology. IT security information systems from unauthorized access, use,
is thus considered a bit broader than cybersecurity. disclosure, disruption, modification, or destruction in order to
provide confidentiality, integrity, and availability (according to
Information System: Applications, services, information NIST).
technology assets, or other information handling components
(according to ISO). Important note: Throughout the whole criterion we always
Cybersecurity: Body of technologies, processes and practices according to the definitions above. For the appraisal of the
designed to protect networks, systems, computers, programs
115 / 252
"cybersecurity" equally.
References
SASB Data Security: "The entity shall describe its approach
to addressing data security risks and vulnerabilities it has
The document(s) you attached will be used to verify your identified, including, but not limited to, operational
response. procedures, management processes, structure of products,
selection of business partners, employee training, and use of
• The supporting documents do not need to be technology." Source: SASB
available in the public domain.
• If a question text field is available, a comprehensive
answer in that field can be accepted instead of a
supporting document. IRIS+ - OI5102
• Any response that cannot be verified in the attached SASB - FN-CF-230a.3, FN-EX-550a.3, TC-TL-230a.2
document(s) or via the information provided in the
related question text field (if available) will not be
accepted.
116 / 252
IT Security/ Cybersecurity Process & Infrastructure
Assessment Focus
Question Rationale
Due to the current trend of digitization, including but not security/cybersecurity has become a financially material
limited to cloud computing, online marketplaces and issue that must be diligently managed to protect corporate
payments, etc., it is crucial that access to networks, IT value. The costs of cyberattacks are manifold and can impact
systems and data is assured at all times. As a result, lower the company in different ways. Internal costs are operational
than agreed upon system performance or service disruptions costs and relate to dealing with cybercrime and incidence
can result in higher costs and reputational risk for companies. prevention. External costs include the consequences of the
The main risks stem from technical failure, human error, cyber-attack such as the loss or theft of sensitive
malicious attacks, weather events, natural disasters or information, operations' disruption, fines and penalties,
terrorist attacks. Managing such risks, including contingency infrastructure damage or revenue losses due to loss of
plans, is crucial to ensuring business continuity. customers. Thus, ensuring the security and resilience of
networks and information systems is critical.
Over the past decade, the number of information security
breaches has grown exponentially with some attacks The question focuses on how well companies are prepared to
reaching unprecedented scales and the cyber threat prevent major IT infrastructure and information
landscape continues to grow and evolve, abusing existing and security/cybersecurity incidents and if they can react
new technologies and exploiting vulnerable users. These appropriately in the event of such events.
incidents and the related costs have shown that information
Question Layout
This question assesses if companies have the right processes in place to prevent IT system interruptions and cyberattacks and if they
are well-prepared to react in case of such events.
□ Incident response
Do you have business continuity / contingency plans and incident response procedures in place and how often do you test them?
Please provide supporting evidence of how often these plans/procedures are tested.
□ Yes, and we test them at least semi-annually

□ Yes, and we test them at least annually
□ Yes, but frequency is less than yearly or not specified
□ No, we do not have such plans and procedures in place
Certification
Is your IT infrastructure and information security management system certified to ISO 27001, NIST or similar?
□ Yes, the following percentage of our IT infrastructure has been certified: _______
□ No, our IT infrastructure has not been certified.
External verification and Vulnerability Analysis

Please indicate if there are other additional procedures implemented to assure the security of the IT infrastructure / information
security management systems.
□ Our IT infrastructure and information security management systems have been audited by external auditors in the
last fiscal year. Please provide letter of opinion from the external auditor.
□ We conduct third-party vulnerability analysis. Please provide supporting evidence:
□ As part of third-party vulnerability analysis, we conduct simulated hacker attacks. Please provide supporting
evidence.
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Breaches
Has your company experienced breaches of information security?
□ We collect data on information security/cybersecurity breaches.

Please note that if you did not have any information breaches, 0 should be entered in the corresponding box in the table. If you do not
know the information, please leave the box empty. See the information text for more information.
2023
Total number of information security breaches
Total number of clients, customers and employees affected by the breaches
□ We do not collect data on information security/cybersecurity breaches
Question-Specific Guidance & Definitions compromised in a data breach (accounts that the entity
cannot verify as belonging to the same client, customer or
IT security: IT security is the process of implementing
employee shall be disclosed separately).
measures and systems designed to securely protect and
safeguard information utilizing various forms of technology. IT
Important note: Throughout the whole criterion we always
security is thus considered a bit broader than cybersecurity.
according to the definitions above. For the appraisal of the
Information System: Applications, services, information
technology assets, or other information handling components
and "cybersecurity" equally.
(according to ISO).
Data Requirements
Cybersecurity: Cybersecurity is the body of technologies,
processes and practices designed to protect networks, Vulnerability analysis: We expect to see evidence that a
systems, computers, programs and data from attack, damage vulnerability analysis was conducted and that this analysis
or unauthorized access (according to SEC). included simulated hacker attacks. The analysis and testing
should be performed by a third party with appropriate
Information security: The protection of information and certification.
information systems from unauthorized access, use, Please note: Non-IT companies can also calculate the
disclosure, disruption, modification, or destruction in order to percentage of certified IT infrastructure based on the
provide confidentiality, integrity, and availability (according to percentage of certified IT products by external vendors.
NIST).
Vulnerability Analysis: The analysis that a company conducts • The document(s) you attached will be used to verify
for defining, identifying, classifying, and prioritizing the qualitative part of your response. If a question
vulnerabilities in computer systems, applications, and text field is available, a comprehensive answer in
network infrastructures. This provides the organization doing that field can be accepted instead of a supporting
the assessment with the necessary knowledge, awareness document. Any qualitative response that cannot be
and risk background to understand the threats to its verified in the attached document(s) or via the
environment and react appropriately. information provided in the related question text
field (if available) will not be accepted.
Information security breaches: These are defined as • Quantitative figures provided in the response do not
unauthorized access to computer data, applications, need supporting evidence. You may still provide a
networks, devices, protected systems and data. reference using the reference clip. This could
Cybercriminals or malicious applications bypass security include examples of the underlying calculations or
mechanisms to reach restricted areas. approaches to data aggregation used to compile the
Number of clients, customers and employees affected: The • The supporting documents do not need to be
entity shall disclose the total number of unique clients, available in the public domain.
customers and employees who were affected by data
breaches, which includes all those whose personal data was
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References Standards & Frameworks
External management standards and frameworks include but
ESG Disclosure Standards (China) - G.2.1.5 Data security
are not limited to:
ISO/IEC 27001:2022 Information technology Security SASB - CG-EC-230a.1, CG-EC-230a.2, CG-MR-230a.1, CG-
techniques Information security management systems MR-230a.2, FB-FR-230a.1, FB-FR-230a.2, FN-CB-230a.1,
Requirements
FN-CF-230a.1, FN-CF-230a.3, FN-EX-550a.2, HC-DY-230a.3,
Barrett, M. (2020), Framework for Improving Critical HC-MC-230a.2, IF-EU-550a.1, RT-AE-230a.1, RT-AE-230a.2,
Infrastructure Cybersecurity Version 1.1, NIST Cybersecurity SV-ED-230a.1, SV-ED-230a.3, SV-PS-230a.1, SV-PS-230a.3,
Framework, [online],
https://doi.org/10.6028/NIST.CSWP.04162018, TC-HW-230a.1, TC-IM-230a.1, TC-IM-230a.2, TC-SI-230a.1,
https://www.nist.gov/cyberframework TC-SI-230a.2, TC-SI-550a.2, TC-TL-230a.1, TC-TL-230a.2
119 / 252
04
Environmental Dimension
Environmental Policy & Management
Environmental Management System (EMS) refers to the environmental resource management. Companies that have
management of an organization's environmental programs in adopted an EMS as a management tool are more likely to
a comprehensive, systematic, planned and documented improve their environmental performance in a cost-effective
manner. It includes the organizational structure, planning and way and to reduce the risk of incurring fines or penalties for
resources to develop them, and the procedure for the not complying with environmental legislation.
implementation and management of the company's policy on
Environmental Policy
Assessment Focus
Question Rationale
Environmental Management System (EMS) and related public
This question identifies the critical elements of
preparedness and commitment to measure and reduce the Environmental Management System (EMS) as well as
environmental impact of its operations. Companies that have commitments that are defined in the group-wide, public
adopted an environmental policy as a management tool are environmental policy.
more likely to improve their environmental performance in a
structured and systematic way.
Question Layout
To ensure a successful implementation of a reliable and robust Environmental Management System (EMS), key organisational
elements as well as high level commitments need to be defined in a public policy. Does your company have a public environmental
policy which covers the following elements of Environmental Management System?
□ Yes, we have a public environmental policy, and it defines the following elements.
□ Commitment and oversight to implementation of environmental management policy and/or improving environmental
performance. Please select the highest committing decision-making body:
□ Roles and responsibilities for implementing environmental management policy
□ Ensuring compliance with relevant environmental laws and regulations
□ Commitment to continuous improvement of environmental performance
□ Commitment to set targets and objectives to reduce environmental impacts
□
environmental impacts
□ Training for employees to understand the impacts of their work activities to the environment
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Environmental Management System (EMS): Management of This question requires supporting evidence from the public
an organization's environmental programs in a domain. The information provided has to be included in your
comprehensive, systematic, planned and documented public reporting (e.g., annual report, sustainability report,
manner. It includes the organizational structure, planning and integrated report, company publications, separate fuel
resources to develop them, and the procedure for the efficiency strategy document) or corporate website.
implementation and management of the company's policy on
environmental management. Any response that cannot be verified in the attached public
Environmental Policy: Group-wide, public policy that
describes the intentions and directions related to
environmental impacts and performance defined by top Standards & frameworks
management. CSRD - E1-2 24 ESRS 2 MDR-P, E1-2 25(a) AR 16-AR 18, E1-2
25(b) AR 16-AR 18, E1-2 25(e) AR 16-AR 18, E1-3 28, ESRS 2
Commitment and oversight: A statement that the MDR-P 65a, ESRS 2 MDR-P 65c
commitment/policy is approved, overseen, reviewed, or IRIS+ - OD4091, OD4108, OI1984, OI3943, OI4136, OI4531
adopted by the board of directors or executive management. SASB - EM-CO-160a.1, EM-EP-530a.1, EM-MM-160a.1, EM-
A policy can also be signed by the respective director. RM-530a.1, EM-SV-530a.1, RT-CH-530a.1, SV-HL-160a.2
Data Requirements UNGC Questionnaire - E1, E1.1, E3, G1, G2, G4
121 / 252
Coverage of Environmental Management Policy
Assessment Focus
Question Rationale
Corporate environmental guidelines are an important environmental performance in a structured and systematic
way.
the environmental impact of its operations. Companies that This question identifies the scope of such requirements in
have adopted corporate environmental guidelines as a terms of operations, corporate processes and supply chain.
management tool are more likely to improve their
Question Layout
Does the company have a policy on environmental management and is it available publicly?
□ Yes, the company has a policy on environment management. Please indicate where this information is available in
□ Production operations and business facilities

□ Products and services
□ Distribution and logistics
□ Management of waste
□ Suppliers, service providers and contractors
□ Other key business partners (e.g. non-managed operations, joint venture partners, licensees, outsourcing
partners, etc.)
□ Due-diligence, mergers and acquisitions
□ Other, please specify
New projects: All new initiatives taken on by your company,

and may include new facilities as well as other types of new Any response that cannot be verified in the attached public
areas for your company. document(s) will not be accepted.
Data Requirements Standards & frameworks

Supporting evidence: CSRD - E1-2 24 ESRS 2 MDR-P, E1-2 25(a) AR 16-AR 18, E1-2
This question requires supporting evidence from the public 25(b) AR 16-AR 18, E1-2 25(e) AR 16-AR 18, E1-3 28
domain. The information provided has to be included in your EU Taxonomy Multiple Objectives & Activities - DNSH (4)
public reporting (e.g., annual report, sustainability report, IRIS+ - OI5102
integrated report, company publications, separate fuel SASB - EM-CO-150a.8, EM-EP-160a.1, EM-MD-160a.1
efficiency strategy document) or corporate website. UNGC Questionnaire - E1.1
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Verification of Environmental Programs
Assessment Focus
Question Rationale
A verified/audited EMS reflects a company's internal and focuses on identifying whether the company has
external commitment towards the monitoring of implemented, verified and certified its environmental
environmental data. Further, the verification process can management system to ensure the credibility of the
facilitate improvements to a company's EMS, improving procedures and systems in place.
efficiency and coverage. Our question on audit verification
Question Layout
Please indicate how your Environmental Management System (EMS) is certified / audited / verified and indicate the coverage of this
verification for the selected standard. Please indicate where this information is available in your public reporting or corporate
website.
Please note that the total coverage for all three alternatives should not exceed 100% - to avoid double-counting, for the parts of your
operations with multiple certifications/types of verification, only mark one of the three options: indicating the coverage of
international standards first, followed by third-party verification and then internal verification. Coverage should be relative to global
operations and not only a single subsidiary, region or site. Please also note that the requested verification only pertains to your
Environmental Management System(s), not to your environmental data or reporting.
□ Our Environmental Management System (EMS) is certified / audited / verified and the information is publicly available.
Please indicate what the coverage figures below are based on (e.g. % of group-wide operations, group-wide revenues, group-wide
production sites, total employees, etc.):
Certification / Audit / Verification Coverage (%) Examples of Certification documents
EMS is verified through international

standards (e.g. ISO 14001, JIS Q 14001,
EMAS certification). Please specify:
Third party certification / audit
/ verification by specialized companies.
Please specify:
Internal certification / audit / verification
by company's own specialists from
headquarters. Please specify:
Total (should not exceed 100%)
Data Requirements
Please note that the total coverage for all three alternatives coverage of international standards first, followed by third-
should not exceed 100 % - to avoid double-counting, for the party verification and then internal verification.
parts of your operations with multiple certifications/types of
verification, only mark one of the three options: indicating the
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Coverage should be relative to global operations and not only • This question requires supporting evidence from the
a single subsidiary, region or site. included in your public reporting (e.g., annual
report, sustainability report, integrated report,
Please also note that verification only pertains to your company publications, separate fuel efficiency
strategy document) or corporate website
Environmental Management Systems, not the verification of
environmental data or reporting. • Any response that cannot be verified in the attached
public document(s) will not be accepted.
Note:
We accept RC 14001 for marking - EMS verified through
international standards.
We do not accept ISO 50001, LEED or ISO 14064 or any other CSRD - E1-2 25(e) AR 16-AR 18, E1-3 28
certification of energy or GHG management or product EU Taxonomy - Multiple Objectives & Activities - Substantial
specific verification/certification. Contribution & DNSH
Supporting evidence: IRIS+ - OI1254, PD2756
124 / 252
Energy
In the last century, there has been an unprecedented increase liabilities. It can also mean companies are better prepared for
in the use of natural resources and materials. Producing more future environmental regulations. The key focus of this
with less material is essential for many industries affected by
the increasing scarcity of natural resources. Resource consumption, efficiency and circularity across business
efficiency and circularity can enha operations.
competitiveness through reduced costs and environmental
Energy Management Programs
Assessment focus
Question Rationale
By integrating energy management programs into business requires a commitment from all levels of the organization,
practice, companies can establish a robust process to especially top management. This involves cultural changes
continuous improvement of energy performance. Energy within the entire organization.
performance is a concept which is related to energy
efficiency, energy use and energy consumption. By improving This question identifies the set of actions that ensure a
energy performance and associated energy costs, companies robust, credible and reliable energy management program. It
can improve their competitiveness. In addition, improving aims to provide a systematic, data-driven and facts-based
energy performance leads to meet climate change mitigation process, focused on continually improving energy
goals by reducing their greenhouse gas emissions. performance that can transform the way companies manage
energy use and energy consumption.
Successful implementation of energy management programs
supports a culture of energy performance improvement that
Question Layout
Does the company have energy management programs and are they available publicly?
□ Yes, the company has energy management programs that cover the following elements. Please indicate where this
□ Energy audits to identify opportunities for improving energy performance
□ Quantified targets to address energy savings
□ Actions to reduce the amount of energy use
□ Evaluation of progress in reducing energy consumption
□ Use of clean or green energy
□ Investments in innovation or R&D to decrease energy consumption
□ Energy efficiency training provided to employees to raise awareness of energy consumption reduction
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Question-Specific Guidance & Definition
Energy audits: Process that analyzes energy efficiency, Innovation or research and development to decrease energy
energy use and energy consumption based on data and consumption: Procedures to consider improvement
evidence. This process allows firms to determine areas of opportunities and operational control in the design of new,
significant energy use and identify opportunities for modified and renovated facilities; equipment; systems; and
improving energy performance. energy-using processes: considering energy performance in
the design of facilities, equipment, systems or energy-using
processes within the scope and boundaries of the company
Quantified targets: Objectives with specific, measurable and
and considering on-site renewable energy production and
quantifiable energy performance improvement targets to
less-polluting types of energy options for new facilities,
improved technologies and techniques.
electricity consumption by 3 % by the end of the year, 2 %
plant efficiency improvement by fourth quarter). Although
Energy efficiency training: Training focused on raising
emissions reduction targets can be a result of energy
efficiency measures, this question solely covers energy
energy behavior and lead to cultural change aiming to reduce
consumption reduction targets.
energy consumption.
Actions to reduce the amount of energy used: Concrete and

targeted actions focused on reducing energy consumption. Disclosure Requirements
These can include modification or renovation of facilities This question requires supporting evidence from the public
(e.g., warehouse, factories, office), equipment (e.g., engines, domain. The information provided has to be included in your
boilers), systems (e.g., lighting, steam, transport) and energy- public reporting (e.g., annual report, sustainability report,
integrated report, company publications) or corporate
using processes, or qualitative objectives related to people website.
energy behavior, cultural change or operation of the systems
and equipment responsible for substantial energy document(s) will not be accepted.
consumption.
Evaluation of progress in reducing energy References

consumption: Comparison of performance before and after
ISO 50001 Energy Management Systems
the implementation of action plans
Clean energy: The type of energy that does not release Standards & Frameworks
pollutants into the air.
ESG Disclosure Standards (China) - E.1.3.4 Energy saving
management
Green energy: Resources that come from natural sources,
EU Taxonomy - Multiple Objectives & Activities - Substantial
such as the sun. Renewable energies are both clean and
Contribution & DNSH
green energy since they come from sources that are
GISD - Real Estate: Energy efficiency measures
constantly being replenished, such as hydropower, wind
IRIS+ - OI4531
power or solar energy. Although these measures do not
UNGC Questionnaire - E3
represent an energy performance improvement per se, the
consumption of renewable energy has positive environmental
effects, hence off-site renewable energy is accepted.
126 / 252
Energy Consumption
Assessment Focus
Question Rationale
In the last century, there has been an unprecedented increase future environmental regulations. In this question, we are
in the use of natural resources and materials. Producing more capturing the total non-renewable and total renewable
with less material is essential for many industries affected by energy consumption, assessing the overall trend of
the increasing scarcity of natural resources. Resource consumption, as well as the target set for the current
efficiency an financial year.
competitiveness through reduced costs and environmental
liabilities. It can also mean companies are better prepared for
Question Layout
Please complete the following table about total energy consumption. For each row in the table, it is mandatory that the values
provided are in the same unit. Please see the Information Button for definitions of the cost options. Also, please ensure that you have
correctly filled in the Company Information section at the beginning of the questionnaire, and that the coverage in the table below is
related to the denominator relevant for your company as indicated in that section.
Total energy consumption Unit FY FY 2021 FY 2022 FY 2023 What was your
2020 target for FY 2023?
Total non-renewable energy MWh
consumption
Total renewable energy MWh
consumption
Data coverage (as % of Percentage of
denominator)
PUBLIC REPORTING
DATA CONSISTENCY
□ We report publicly on this information, but the data in the table above differ from our publicly reported figures. Please
provide an explanation in the comment box for this difference: ___
□ We have a temporary coverage reduction or target challenge due to corporate actions. Please briefly explain if a merger,
acquisition, divestment, etc. has temporarily caused a reduction in your ability to report optimal coverage or caused your
target to appear abnormal: ___
□ We are not able to report this information in absolute terms; the information provided in the table above is normalized data.
For the purpose of this question, please always provide absolute figures if available.
127 / 252
Total non-renewable energy consumption: This is the sum of considered feedstocks and should not be counted.(Such as
non-renewable consumption of fuel (excluding feedstocks), coke used as a reducing agent)However, all fuels consumed
consumption of non-renewable purchased or acquired for energy, i.e., combusted, that are derived from fuel
electricity, and consumption of non-renewable purchased or feedstocks, e.g., blast furnace gas, should be counted.
acquired heat, steam and cooling.
This table is for gross energy consumption data only. You
Total renewable energy consumption: This is the sum of should not provide net consumption nor deduct for energy
consumption of renewable fuel (excluding feedstocks), produced or exported from the organizational boundary.
consumption of renewable purchased or acquired electricity, Because feedstock fuels are excluded from this question, this
consumption of renewable purchased or acquired heat, approach should not lead to double counting. Companies
steam and cooling and consumption of self-generated non- shall use the total or gross electricity purchases from the
fuel renewable energy. grid rat
Renewable energy: This is energy taken from sources that are would therefore include self-generated energy (any emissions
inexhaustible such as wind, solar, hydropower, geothermal, reflected in scope 1) and total electricity purchased from the
biomass and marine (tidal and wave energy), as defined in the grid (electricity). It would exclude generation sold back to the
GHG Protocol. Please note hydrogen should not be included if grid.
it is derived from fossil fuels. Similarly, waste energy should
not be included if it is derived from fossil fuels. Purchased or acquired electricity, steam, heat, cooling:
• This includes the consumed electricity, heat, steam,
Non-Renewable energy: This is all energy not identified as and/or cooling that was purchased or acquired, i.e.,
deriving from renewable sources, e.g., coal, oil, natural gas, brought into the organizational boundary. This excludes
etc. Please note that blended fuels deriving from both the consumption of electricity, heat, steam, or cooling
renewable and non-renewable sources should be split by the that was produced by the organization, i.e., from inside
proportion contained from each source. Nuclear energy is not the organizational boundary. It also excludes purchased
considered as renewable energy and should be reported or acquired electricity, heat, steam, or cooling that is not
under total non-renewable energy. Please note that direct consumed inside the organizational boundary.
consumption of nuclear fuel should not be included. Fuels Purchased or acquired electricity, heat, steam, or
(excluding nuclear) should be covered, including fleet fuel. cooling that is wasted should still be counted as
Consumption of purchased or acquired electricity, steam consumption.
heat, and/or cooling from nuclear sources should be included. • Purchased or acquired electricity, steam, heat, and
cooling are aligned with the boundary for scope 2
Self-generated non-fuel renewable energy: If your emissions. The consumption of fuel (excluding
organization produces renewable energy that is not based on feedstocks) should be entered if the fuel was consumed
fuel (such as solar, wind, hydro, geothermal, marine), then inside your organizational boundary in the last fiscal year
any consumption of this energy should be entered under total and is aligned with the boundary for scope 1 emissions.
renewable energy. All forms of non-fuel renewable energy, Therefore, in this question, we would like to capture your
electricity, heat, steam, or cooling should be included under energy consumption for scope 1 and scope 2.
total renewable energy. • Specific information on these energy carriers can be
found in section 5.3.1 and Appendix A of the GHG
Excluding feedstocks: Fuels consumed as feedstocks are Protocol Scope 2 Guidance.
fuels that are not combusted for energy purposes. All fuel •
consumed for energy purposes inside the organizational organization has received the energy from a third party.
boundary should be included, regardless of whether the fuel This rules out energy that is sourced from within the
was purchased or produced by the organization. If a fuel is organizational boundary. It should be noted that
consumed as a feedstock for the production of another fuel, purchased or acquired heat does not include the heat
then the feedstock should not be included, but combustion of content, or calorific value, of fuels that are purchased or
the produced fuel should be included. Ultimately, if a fuel is acquired by the organization. This is accounted for at the
combusted, i.e., consumed for energy purposes and not as a point of fuel consumption, which falls inside the Scope 1
feedstock, then it should be included. For example, naphtha boundary. You should also be aware that steam, heat or
and ethane are feedstocks that may be converted into
petrochemical products such as ethylene, and should not be
included. The steel industry is a special case because coke for if it is consumed.
and fuel injectants consumed at the blast furnace serve as • If your organization produces renewable energy that is
feedstocks and a source of energy. These fuels are not based on fuel (such as solar, wind, hydro,
128 / 252
geothermal, marine), this energy consumption should be Data Requirements
included in total renewable energy consumption.
Disclosure requirements for partially public question.
Consumption of renewable fuels (such as solid and liquid
Additional credit will be granted for relevant publicly available
biofuels and biogas) also should be included. All forms of
evidence covering the following aspect of this question:
non-fuel renewable energy - electricity, heat, steam, or
• Total non-renewable energy consumption for at least
cooling shall be included under non-renewable energy.
the most recent reported year.
Leased Assets: Guidance for how to handle leased assets and

Third-party verification: For third-party verification, we
spaces can be found on page 36 of the GHG Scope 2
expect that data in the most recent year reported has been
Protocol, (5.2.1).
third-party verified and that relevant documentation is
attached showing this verification. Internal audits or
Renewable Energy Credits: These should fall under MWh from
verification will not be considered.
renewable sources. RECs, RECs from Power Purchase
Agreements, energy attribute certificates, contractual
Please note: In case the company has reported a value of zero
instruments, TIGRs, and unbundled certificates should be
in the table, third-party verification or supporting evidence is
reflected under MWh from renewable sources.
required (e.g., comprehensive comment, internal
documentation or public reporting) to substantiate the zero
Units and conversion:
reported.
• The most common unit for electricity are Watt-hours. 1
MWh is equal to 1,000,000 Watt-hours, which is equal to
For this question, we encourage you to provide evidence that
1,000 kWh (kilo-Watt-hours).
is publicly available and may grant additional credit for
• If your raw data is in energy units other than MWh, such
publicly available evidence.
as Giga-Joules (GJ) or British Thermal Units (Btu), then
you should convert to MWh. For example, 1 Giga-Joule
Please note: In cases where the company is classified within
(GJ) = 0.277778 MWh, so if your data is in GJ then you
the Banks (BNK), Financial Services (FBN), Insurance (INS), or
should multiply your data by 0.277778. If your data is in
Professional Services (PRO) industries, the score obtained in
million Btu, then you need to multiply your data by
this question will not contribute to the final score of the
0.29307.
company.
• Conversion factors from other energy units are available
from a variety of online calculation tools, including from
IEA and OnlineConversion.com, or from conversion Standards & frameworks
tables such as those in EPA AP-42 (Annex A). CSRD - E1-5 37(a) AR 33-AR 35, E1-5 37(b) AR 33-AR 35, E1-5
• If your raw data is in volume units, e.g., cubic feet or 37(c)i, E1-5 37(c)ii, E1-5 38 c AR 33, E1-5 38(a) AR 33, E1-5
gallons, or in mass units, e.g., kilograms (kg) or pounds 38(b) AR 33, E1-5 38(d) AR 33, E1-5 38(e) AR 33, ESRS 2 MDR-
(lb), then you should convert to energy units using T 80j AR 24 - AR 26
factors for fuel heating/calorific values. These are EDCI - Renewable energy consumption, Total energy
available from numerous sources, some of which are consumption
listed below: ESG Disclosure Standards (China) - E.1.3.2 Non-renewable
energy consumption
IPCC Guidelines for National GHG Inventories (Volume 2, Table GISD - Renewable energy comsumption as percentage of total
1.2, p1.18-1.19) energy consumption
EPA AP-42 (Annex A) GRI Disclosure - 2-5, 302-1
IEA Statistics Manual (Annex 3, p180-183) IRIS+ - OD4091, OI1495, OI1496, OI2496, OI3324, OI8825,
API Compendium (Table 3-8, p3.20-3.21) OI9624
SASB - CG-BF-130a.1, EM-CM-130a.1, EM-IS-130a.1, EM-IS-
• If your raw data for steam is in physical units, such as 130a.2, EM-MM-130a.1, EM-SV-110a.1, F-WU-130a.1, FB-
pounds (lb) or kilograms (kg), then you should convert to AB-130a.1, FB-AG-130a.1, FB-MP-130a.1, FB-NB-130a.1,
energy units. The energy content of steam varies with FB-PF-130a.1, FB-RN-130a.1, HC-DR-130a.1, HC-DY-130a.1,
temperature and pressure. Organizations can refer to IF-RE-130a.1, IF-RE-130a.2, RR-FC-130a.1, RR-PP-130a.1,
The Climate Registry's General Reporting Protocol, RR-ST-130a.1, RT-AE-130a.1, RT-CH-130a.1, RT-CP-130a.1,
Chapter 15, section 15.2, step 1, which explains how to RT-EE-130a.1, RT-IG-130a.1, SV-CA-130a.1, SV-HL-130a.1,
calculate the energy content of steam. SV-LF-130a.1, TC-IM-130a.1, TC-SC-130a.1, TC-SI-130a.1,
• Cooling is frequently purchased in refrigeration-ton TR-AP-130a.1, TR-CL-110a.3, TR-MT-110a.3, TR-RO-110a.2
hours; 1 ton-hour is equal to 12,000 Btu, which is equally SFDR Principal Adverse Impacts - Energy consumption,
to 0.003516 MWh. Energy performance, Share of non renewable energy
consumption and production
129 / 252
UNGC Questionnaire - E10, E4, E4.1 WEF Metrics - Resource circularity
130 / 252
Waste & Pollutants
The shift towards a circular economy continues to grow in when seeking new business opportunities. Additionally,
importance as the waste crisis escalates. From design and measuring waste generated allows companies to track
planning to end of life, the proper treatment of waste can progress, set meaningful targets, better prepare for future
regulation and address stakeholder expectations. The focus
and environmental liabilities. Integrating programs within of this criterion is to identify the management and trends of
company operations to reduce waste is considered one of the waste across business operations.
best practices in minimizing environmental and social impact
Waste Management Programs
Assessment Focus
Question Rationale
This question aims to understand how companies are taking look to close the loop by reusing, recycling, recovering and
steps towards the responsible management of waste within diverting waste, preventing it from entering the landfill and
their operations. Adopting waste reduction programs is seeking new advantageous business opportunities.
critical in improving operational performance and reducing Companies benefit from investing in resources and programs
environmental and social impacts. Ideally, businesses should that address waste through decreased costs, reduced risks,
improved reputation, etc.
Question Layout
Does the company have waste management programs and are they available publicly?
Š Yes, the company has waste management programs that cover the following elements. Please indicate where this
Š Waste audits to identify opportunities for improving waste performance

Š Action plans to reduce waste generation
Š Quantified targets to minimize waste
Š Investment in innovation or R&D to minimize waste
Š Waste reduction training provided to employees
Š Integration of recycling programs to reduce the waste sent to landfill
Š Waste diversion from landfill is certified by an independent accredited body
Question-Specific Guidance & Definitions opportunities for improving energy performance. This might
include record examinations, facility walk-throughs, waste
Operations: Includes any business activity within a
sorting, etc.
such as
production, extraction,manufacturing, management, etc. This
Actions to reduce waste generation: Specific measures
also refers to companies operating solely in office buildings.
focused on reducing waste generation in areas of significant
concern. Focus points are usually identified through a waste
Waste audits: Also called waste assessments, the process of
audit, and as a result, actions are implemented to minimize
identifying the amount and type of waste being generated in a
waste.
determine areas of significant generation and identify
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Quantified targets: Objectives with specific, measurable and composting and minimal amounts through energy production
quantifiable waste performance improvement targets (e.g., via ate is calculated
reduce waste generated by 15% by 2030, reduce the waste by adding the weight of all waste diverted from landfill and
sent to landfill by 5% by the end of the year). These targets dividing it by the total amount of waste diverted plus what is
should be time-bound and include a target year. sent to landfill. Calculation: Weight of diverted waste /
(Weight of diverted waste + Weight of waste set to landfill) x
Investments in innovation or R&D resources to minimize 100 = Diversion rate
waste: This aspect seeks to understand if a company has
allocated monetary, workforce, or other resources to Disclosure Requirements
investigate new ideas or technology aimed at minimizing This question requires supporting evidence from the public
waste generation from business operations. This might domain. The information provided has to be included in your
include sharing which waste-specific projects its research public reporting (e.g., annual report, sustainability report,
and development team is working on or the creation of integrated report, company publications) or corporate
working groups or other initiatives to address waste website.
reduction.
Waste minimization Training: Training provided to employees document(s) will not be accepted.
to raise awareness and better understand the benefits of
reducing waste across operations.
References
Integration of recycling programs to reduce the waste sent to ISO 14001 - https://www.iso.org/standard/60857.html
landfill: Please share what measures have been incorporated
that demonstrate the reprocessing of materials to be used TRUE Zero Waste Certification - https://true.gbci.org/true-
elsewhere in operations. certification-zero-waste
Waste diversion from landfill: Waste diversion is a practice NSF Landfill-Free Verification -
focused on eliminating the operational waste sent to landfill. https://www.nsf.org/sustainability/circularity-waste-
Diverted materials are reduced, recycled, reused, composted materials-management/landfill-free-verification
and/or recovered for productive use. There is also a heavy
emphasis on restructuring operations to eliminate waste from UL Solutions 2799A - https://ul.com/waste-diversion-and-
conception and redesign methods of operating. circular-economy
Waste diversion from landfill certification: Companies Eurofins Zero Waste to Landfill Certificate -
validate waste diversion claims by certifying operations and https://www.eurofins.com/assurance/consumer-
some certify as zero waste to landfill . This typically products/audit-services/environmental/zero-waste-to-
happens on a facility or project-level basis. Certifications may landfill-certification/
have different levels of recognition within them (gold, silver,
bronze); however, they require operations to prove an 85% or GreenCircle Certified Waste Diversion from Landfill
higher diversion rate. We do not expect all operations to be Certification -
certified. This may include, but is not limited to, certifications https://www.greencirclecertified.com/operations-
such as the TRUE Zero Waste Certification (Green Business certifications
Certification Inc.), NSF Landfill-Free Verification, UL
Solutions 2799A, Eeurofins Zero Waste to Landfill Certificate
and GreenCircle Certified Waste Diversion from Landfill
Certification. CSRD - E5-2 20(f)
SASB - EM-CO-150a.8
Diversion rate: This is the level at which a company has UNGC Questionnaire - E3
managed to recover waste otherwise destined for a landfill.
This is typically achieved through reuse, recycling,
132 / 252
Waste Disposal
Assessment Focus
Question Rationale
trends in waste disposal and recycling, specific to each
competitiveness through reduced costs and environmental industry, as well as the target set for the current financial
liabilities. It can also mean companies are better prepared for year.
future environmental regulations. This question addresses
Question Layout
Please provide a breakdown of your company's total solid waste recycled/reused and disposed, disaggregated by the type of disposal
method, for the part of your company's operations for which you have a reliable and auditable data acquisition and aggregation
for some methods, please report these values in the respective rows and leave the other rows blank .
For each row in the table, it is mandatory that the values provided are in the same unit. Please also ensure that you have correctly
filled in the "Company Information" section at the beginning of the questionnaire and that the coverage in the table below is related to
the denominator relevant for your company as indicated in that section.
If you have the EP - Hazardous Waste, EP Ash & Gypsum Waste and / or EP - Mineral Waste questions in your industry
questionnaire, please report information pertaining to these types of waste in those separate questions. If you do not have those
questions in your industry questionnaire, please include all types of data here (e.g., including hazardous waste).
Unit FY 2020 FY 2021 FY 2022 FY 2023 What was your

target for FY 2023?
Total waste recycled/ reused metric tonnes
Total waste disposed metric tonnes
- Waste landfilled metric tonnes
- Waste incinerated with energy metric tonnes
recovery
- Waste incinerated without energy metric tonnes
recovery
- Waste otherwise disposed, please metric tonnes
specify:
- Waste with unknown disposal metric tonnes
method
Data coverage (as % of denominator) percentage of:
PUBLIC REPORTING
□ Our data on total waste disposed and/or waste generated and recycled/reused (for at least the most recent financial year
reported) is publicly available. Please provide supporting evidence or web link.
 Our data has been third-party verified in the most recent financial year reported. Please provide supporting evidence.
133 / 252
DATA CONSISTENCY
□ We are not able to report this information in absolute terms; the information provided in the table above is normalized data.

Total waste recycled/reused: This includes the part of the energy recovery, otherwise disposed), please report
the total waste disposed and the values for those
during extraction and processing of raw materials, disposal methods for which you have reliable data.
manufacturing, consumption of final products or any other The rows for disposal methods without available
human activity), which has been diverted from disposal data should be left blank. The difference between
through preparation for reuse, recycling, composting or other total waste disposed and the sum of the specific
recovery operations (i.e., processing of waste products, disposal methods will be automatically captured in
components or materials to be reused in place of new
products, components or materials that should otherwise Please note that the company will not lose points if
have been used for that purpose). This does not include waste no detailed breakdown of the disposal methods
incinerated with energy recovery (which is expected to be used is available
captured as part of the specific row under total waste
disposed), or waste handled by third-parties (e.g., municipal For companies who have the questions
waste management companies) unless it is clear that the in their
waste is being recycled, prepared for reuse or composted by questionnaire, please do not report information on these
the third- cial data types of waste here but rather, report relevant data for these
types of waste separately in those questions. For example: if
a co
Total waste disposed: This is the total of all waste directed to -
disposal, including waste landfilled, incinerated with energy hazardous waste should be captured in the question on
recovery, incinerated without energy recovery or otherwise
disposed (e.g., deep well injection). It also captures waste do not have those
questions in your industry questionnaire, please include all
municipal waste management companies without any types of waste in this question.
information available on the disposal methods used. For each
method of disposal, the value includes both on and off-site If a company sets long-term but not annual targets, an annual
disposal. target can be estimated based on internal target setting or a
linear distribution. If a company does not have a specific
target on waste disposed but specific (internal or public)
Data Requirements targets on waste generated and/or recycled, the conversion
Specific data requirement for Waste to a waste disposed target is acceptable.
Waste should be reported in dry metric tons of Waste from extraordinary activities should not be considered.
waste, disaggregated by the amount recycled/ reused and the The definition of what is considered to be extraordinary
specific disposal method (waste landfilled, waste incinerated should be consistent with financial reporting. Example: we
with or without energy recovery, waste otherwise disposed or would not expect a pharmaceutical company building its new
waste with unknown disposal method), respectively. headquarters to report the resulting construction waste.
• In case the company reports zero total waste

disposed, third-party verification or supporting Disclosure requirements for partially public
evidence is required (e.g., comprehensive comment, question. Additional credit will be granted for relevant
internal documentation or public reporting) to publicly available evidence covering the following aspect of
substantiate zero waste disposed this question:
• If you only have information available on the waste • Total waste disposed figure (or alternatively, total
disposed by some or no specific disposal methods waste generated and recycled figures ) for at least
(waste landfilled, waste incinerated with or without the most recent reported year. The specific
134 / 252
breakdown of the disposal methods used is not • Environmental data of companies that are fully
required to be publicly available. consolidated must be fully considered irrespective
of the proportion to which they belong to the group.
Third-party verification: For third-party verification, we • Environmental data should refer to the specific
expect that data in the most recent year reported has been company structure of each particular year. There
third-party verified and that relevant documentation is should be no pro-forma backward consolidation of
attached showing this verification. Internal audits or the current company structure.
verification will not be considered. • Environmental data of companies that are sold or
no longer consolidated should be excluded from
Please note: In cases where the company is classified within environmental data as of the reporting period in
the Banks (BNK), Financial Services (FBN), Insurance (INS), or which the company has not been consolidated
Professional Services (PRO) industries, the score obtained in anymore.
this question will not contribute to the final score of the • Environmental data of companies that have been
company. bought should only be included as of the reporting
period in which the company is consolidated
Data Consistency financially for the first time.
• If the environmental performance data reported in • Where environmental data does not cover all
the questionnaire do not correspond to the publicly consolidated activities of the company, the scope
reported figures, the corresponding option should should be indicated together with the
be marked and the discrepancy should be environmental data that is known.
explained. This option should not be indicated if the • Where the reported environmental data deviates
information is not publicly reported at all. from these definitions you are asked to explain in
• If there is a temporary reduction in coverage due to, what way the data provided differs from the
for example, a major acquisition, the corresponding definitions.
box should be marked and the reduction should be • Please ensure that the Company Information
explained. section has been correctly filled in, and that the
• If it is not possible to report the figures in absolute coverage in the table below is based on the same
terms, the data should be reported in relative terms denominator.
and the corresponding box should be ticked. Please
note that information should always be reported in
References
absolute terms if possible, even if it deviates from
public reporting. Directive 2008/98/EC of the European Parliament and of the
• If the data reported are not consistent with the Council (Waste Framework Directive)
definition provided above, the data should be
provided in the table, the option should be marked, Standards & frameworks
and an explanation of how it differs should be
provided in the comment box. CSRD - E5-5 37(a), E5-5 37(d), ESRS 2 MDR-T 80j AR 24 - AR
26
General data requirements ESG Disclosure Standards (China) - E.2.3.3 Non-hazardous
Environmental performance data should cover the activities waste emissions
of the entire company with the same consolidation as used in EU Taxonomy - Circular Economy - 2.7. Sorting and material
financial reporting and must refer to the financial year (e.g., recovery of non-hazardous waste - Substantial Contribution
01/01 to 31/12 for both financial and environmental data) and GISD - Reduction of waste generation, Waste recyled, Waste
be aligned with the figures reported in the Company reused
Information section question. GRI Disclosure - 2-5, 306-4, 306-5

IRIS+ - OI2535, OI4483, OI6192, OI6709, OI8357, OI8843,
In particular, environmental data of group companies should OI9847
follow the following rules: SASB - EM-CM-150a.1, EM-CO-150a.2, EM-IS-150a.1, EM-

MM-150a.4, FB-RN-150a.1, IF-WM-420a.1, RT-CH-150a.1,
• Environmental data of companies that are TC-TL-440a.1, TR-AP-150a.1, TR-AU-440b.1, TR-CL-160a.1
consolidated proportionally must be considered to SFDR Principal Adverse Impacts - Waste, Water, waste and
the proportion at which they are consolidated material emissions
financially. TNFD - A2.1, A23.1, C2.2

UNGC Questionnaire - E4
WEF Metrics - Resource circularity
135 / 252
Water
Water is becoming increasingly scarce, and such scarcity liabilities. It can also mean companies are better prepared for
poses a considerable risk to many sectors. Consideration of future environmental regulations. The key focus of this
water consumption, and exposure to water risks along the criterion is to identify trends of water use and the extent to
which companies have considered their risks and exposure to
competitiveness through reduced costs and environmental water-related issues.
Water Efficiency Management Programs
Assessment Focus
Question Rationale
Water is essential to developing and maintain successful and The purpose of this question is to understand how companies
healthy economies and for human health and wellbeing. In are taking steps towards the properly managing water as a
any responsible business or organization, monitoring water critical resource for their businesses through specific water
use is a key indicator of its environmental sustainability management programs. In their planning processes,
performance. Knowing and managing water challenges can companies must identify opportunities to continually improve
protect a business from significant and unforeseen costs water efficiency performance. Those programs should focus
caused by quantity and quality issues, which could also on reviewing water use , measuring and monitoring water use
restrict business growth and obstruct socio-economic indicators, improving efficiency performance through
benefits. Adequate water management can also protect an reducing, replacing or reusing water in operations, etc.
organization from regulatory breaches and negative
reputational impacts. The scope of this question is limited to direct operations and
does not include the supply chain.
Question Layout
Does the company have water efficiency management programs in place and are they available publicly?
Š Yes, the company has water efficiency management programs that cover the following elements. Please indicate where this
□ Water use assessment to identify opportunities for water efficiency improvements

□ Actions to reduce water consumption
□ Actions to improve wastewater quality
□ Establishment of targets to reduce water use
□ Application of water recycling
□ Awareness training provided to employees on water efficiency management programs

Water efficiency management programs: Include the It should consider the following:
planning and definition of actions that enable businesses to
assess and account for their water use, identifying and Water use assessments:
implementing measures to achieve and improve efficiency and analyzing its water use, identifying activities and
through the systematic management of water. functions of significant water use, determining processes and
services that affect used water quality, and monitoring water
136 / 252
use quantities. These assessments determine the activities Disclosure Requirements
and functions with potential for better water efficiency. Data
gathering, indicators monitoring and the continuous
domain. The information provided must be included in your
reviewing allow for improvements in water efficiency
public reporting (e.g. annual report, sustainability report,
performance. Please refer to ISO 46001 in the References
section
website.
Actions to reduce water consumption: All measures focused
on reducing the amount of water required for business
activities and operations. These can range from actions References
regarding equipment, systems or processes at facility/site • ISO 46001: 2019 - Water efficiency management
level to those concerning employees/staff in office functions. systems Requirements with guidance for use:
Examples include water-saving devices, submeters installed https://www.iso.org/standard/68286.html
in different areas of the plant, pressure reductions at taps, • CEO Water Mandate: https://ceowatermandate.org/
reuse of storm and grey water, rainwater harvesting, reusing
process water for cooling towers, etc.
Actions to improve wastewater quality: The measures CSRD - E3-1 12a AR 16-AR 18
implemented at facility level focused on improving the quality ESG Disclosure Standards (China) - E.1.1.1 Water resource
of wastewater/discharge water. These can refer to managment
improvements at the source (e.g., process improvements), EU Taxonomy - Appendix B - Sustainable Use and Protection
effluent monitoring and periodic sampling, wastewater of Water and Marine Resources
treatment processes (according to type of effluent), water IRIS+ - OI9326
discharge controls, inspections and audits, etc. SASB - EM-EP-140a.2, EM-SV-140a.1, EM-SV-140a.2
SFDR Principal Adverse Impacts - Water, waste and material
Establishment of targets to reduce water use: A water emissions
efficiency management program will allow for efficiency
improvements based on quantitative, time-bound water
reduction targets. We expect companywide targets or site-
specific targets that clearly cover the majority of operational
sites.
Application of water recycling: Companies can benefit from

water reuse and recycling, that is, the process by which
wastewater produced from one source is treated to be reused
in the same process or recycled for another. Various methods
for reusing or recycling industrial water are available,
depending on water quality requirements, space constraints
and budgetary considerations.
Awareness training provided to employees on water

efficiency management programs: To help educate and
engage employees regarding water efficiency management
and conservation. This training should make staff aware of
how to reduce water consumption in their daily jobs as well as
able to identify problems and innovate solutions to reduce
water use within the company. General references to
criterion.
137 / 252
Water Consumption
Assessment Focus
Question Rationale
Water is becoming increasingly scarce, and such scarcity environmental liabilities. It can also mean companies are
poses a considerable risk to many sectors. Considering water better prepared for future environmental regulations.
withdrawal, consumption and discharge practices can
Question Layout
Please provide your company's total fresh water consumption, including data for water discharge and withdrawal. Please refer to the
information button for additional information. For each row in the table, it is mandatory that the values are provided in the same unit.
Also, please ensure that you have correctly filled in the Company Information section at the beginning of the questionnaire, and that
the coverage in the table below is related to the denominator relevant for your company as indicated in that section.
Water consumption Unit FY 2020 FY 2021 FY 2022 FY 2023 Please indicate what
was your target for
FY 2023?
A. Water Withdrawal: (excluding Million cubic
saltwater) meters
B. Water Discharge (excluding Million cubic
saltwater) meters
C. Withdrawal: Fresh groundwater Million cubic
meters
Total Net Fresh water Million cubic
consumption (A-B) meters
Data Coverage Percentage
of
Public Reporting
Third-Party Verification
□ Our data has been third-party verified in the most recent financial year reported. Please provide
supporting evidence.
Data Consistency
□ We are not able to report this information in absolute terms, the information provided in the table above is normalized data.
138 / 252
Question-Specific Guidance & Definitions question will not contribute to the final score of the
company.
Water Withdrawal (excluding saltwater): Water Withdrawal
is defined as the sum of :
Data consistency
• If the environmental performance data reported in the
i. Fresh surface water, including rainwater, water
questionnaire does not correspond to the publicly
from wetlands, rivers, and lakes
reported figures, the corresponding option should be
ii. Groundwater-renwable and non-renewable
marked and the discrepancy should be explained.
iii. Produced/Entrained water
This option should not be indicated if the information is
iv. Third Party Sources
not publicly reported at all.
• If there is a temporary reduction in coverage due to, for
Fresh surface water: Fresh Surface water, including
example, a major acquisition, the corresponding box
rainwater,water from wetlands, rivers, lakes and freshwater
should be marked and the reduction should be
that require minimal treatment to be acceptable for domestic
explained.
or agriculture uses.
• If it is not possible to report the figures in absolute
terms, the data should be reported in relative terms
Ground water-renewable and non renewable: Ground water
that can be recovered from underground
note that information should always be reported in
Produced/Entrained water: Produced water , reinjected
public reporting.
produced water
General data requirements

Third party sources: Municipal water, local third-party water
Environmental performance data should cover the activities
purchase, city water from public water department, trucked
of the entire company, with the same consolidation as used in
water purchased, tap water and reclaimed water.
financial reporting and it must refer to the financial year (e.g.,
01/01 to 31/12 for both financial and environmental data) and
Water Discharge (excluding saltwater): The water leaving the
be aligned with the figures reported in the Company
being released to surface water,
Information section
groundwater, or third parties, during the reporting year.
Target: We require the absolute target for the most recent

Total Net Fresh Water Consumption: = Water Withdrawal
reporting year. If your company has a multiple year and/or
(excluding saltwater) Water Discharge (excluding saltwater)
relative target, please extrapolate what the target value
would have to be for the last financial year to make sure you
Data Requirements are progressing well towards achieving the target by the end
• If the company is reporting on brackish surface of the target period.
water/seatwater/saltwater, please deduct it from
water withdrawal and water discharge, because we In particular, environmental data of group companies should
want to capture only Total Net Fresh Water
follow the following rules:
Consumption.
• Environmental data of companies that are
• Third-party verification: For third-party verification, consolidated proportionally must be considered in
we expect that data in the most recent year proportion to how they are consolidated financially.
reported has been third-party verified and that • Environmental data of companies that are fully
relevant documentation is attached showing this consolidated must be fully considered irrespective of
verification. Internal audits or verification will not the proportion to which they belong to the group.
be considered. • Environmental data of business travel other than by
• Please note: If the company has reported a value of owned and/or operated fleet should not be included
zero in the table, third-party verification or unless specifically asked for.
supporting evidence is required (e.g., • Environmental data should refer to the specific
comprehensive comment, internal documentation company structure of each particular year. There
or public reporting) to substantiate the zero should be no pro-forma backward consolidation of the
reported. current company structure.
• Please note: In cases where the company is • Environmental data of companies that are sold or no
classified within the Banks (BNK), Financial longer consolidated should be excluded from
Services (FBN), Insurance (INS), or Professional environmental data as of the reporting period in which
Services (PRO) industries, the score obtained in this the company was no longer consolidated.
139 / 252
• Environmental data of companies that have been &idtype=ThemeID&incchild=1&microsite=0&otype=Guidanc
bought should only be included as of the reporting e&tags=TAG-597%2CTAG-607%2CTAG-599
period in which the company was consolidated Minerals Council of Australia (MCA), Water Accounting
financially for the first time. Framework, User Guide Version 2.0, 2022:
• Where environmental data does not cover all https://minerals.org.au/wp-content/uploads/2022/12/MCA-
consolidated activities of the company, the scope Water-Accounting-Framework-User-Guide-2.0-2022.pdf
should be indicated together with the environmental
data that is known.
• Where the reported environmental data deviates from
these definitions you are asked to explain in what way CSRD - E3-3 AR 23 a; AR 24; AR 26, E3-3 AR 23 b; AR 24; AR
the data provided differs from the definitions. 26, E3-4 28a, E3-4 AR 32, ESRS 2 MDR-T 80j AR 24 - AR 26
• If a company publicly reports on long-term but not ESG Disclosure Standards (China) - E.1.1.2 Fresh water
annual targets, an annual target must be estimated consumption, E.2.1.3 Wastewater discharge
based on internal target setting or a linear distribution. EU Taxonomy - Water Resources - 2.1. Water supply -
• The data must be provided in the unit indicated in the Substantial Contributions
question. If the company is tracking the specific GISD - Water use efficiency
indicator in a different unit, the unit converter must be GRI Disclosure - 304-4
used to convert the data into the preferred unit. IRIS+ - OD4091, OI0263, OI0386, OI1697
• Please ensure that the Company Information section SASB - CG-EC-130a.2, CG-HP-140a.1, EM-CM-140a.1, EM-
has been filled in correctly, and that the coverage in CO-140a.1, EM-EP-140a.1, EM-IS-140a.1, EM-MM-140a.1,
the table below is based on the same denominator. EM-RM-140a.1, EM-SV-140a.1, FB-AB-140a.1, FB-AG-
Disclosure Requirements 140a.1, FB-MP-140a.1, FB-NB-140a.1, FB-PF-140a.1, FB-
RN-140a.1, IF-EU-140a.1, IF-RE-140a.1, IF-RE-140a.2, RR-
BI-140a.1, RR-PP-140a.1, RR-ST-140a.1, RT-CH-140a.1, RT-
evidence covering the following aspect of this question: CP-140a.1, SV-HL-140a.1, TC-ES-140a.1, TC-IM-130a.2, TC-
SC-140a.1, TC-SI-130a.2, TC-SI-230a.1
• Total Net Fresh Water Consumption for at least the
SFDR Principal Adverse Impacts - Water, waste and material
most recent reported year.
emissions
References TNFD - A3.0, C2.1
UNGC Questionnaire - E13, E4
CDP -Water Security 2023:
https://guidance.cdp.net/en/guidance?cid=35&ctype=theme
140 / 252
Climate Strategy
Most industries will be impacted by climate change, albeit to Additionally, many questions in this criterion are aligned with
a varying degree. The need for robust strategies to meet the the Task Force on Climate-related Financial Disclosure (TCFD)
scale of the challenge is growing ever more significant. There which published in 2017 a set of recommendations for
is increasing focus not only on identifying the risks and voluntary and consistent climate-related financial risk
opportunities of climate change but also managing these disclosures in mainstream reporting. While the developed
risks, setting targets, and ensuring appropriate governance disclosure recommendations are voluntary, investors
and oversight at all levels of the business. As the number of demand for companies to report in line with TCFD is growing
climate-related mandatory and voluntary disclosure exponentially and governments are starting to move toward
frameworks and standards increase, companies must remain requiring TCFD disclosures through regulation.
vigilant at not only assessing their own exposure to climate
but also documenting this in a way that meets disclosure Finally, the EU action plan on sustainable finance and its EU
requirements. Taxonomy Regulation on the establishment of a framework to
The majority of the questions in this criterion have been facilitate sustainable investment have also been considered
developed in alignment with the CDP methodology in the further development of this criterion. (Regulation (EU)
(https://www.cdproject.net). 2020/852).
Direct Greenhouse Gas Emissions (Scope 1)
Assessment Focus
Question Rationale
The purpose of this question is to capture the company's regulatory pressure has led to the mandatory disclosure of
direct greenhouse gas (Scope 1) emissions and assess the certain emissions. By disclosing emissions, investors and
overall trend. Emissions can serve as a critical indicator of a stakeholders can ascertain a company's climate risks and
company's impact on the climate. Increasingly, the disclosure identify trends in emissions reduction to benchmark against
of emissions is expected from investors, and growing competitors.
Question Layout
Please provide your company's total direct greenhouse gas emissions (DGHG SCOPE 1) for the part of your company's operations for
which you have a reliable and auditable data acquisition and aggregation system. Please refer to the information button for additional
clarifications. For each row in the table, it is mandatory that the values provided are in the same unit. Also, please ensure that you
have correctly filled in the Company Information section at the beginning of the questionnaire, and that the coverage in the table
below is related to the denominator relevant for your company as indicated in that section.
Direct GHG (Scope 1) Unit FY 2020 FY 2021 FY 2022 FY 2023 What was your
target for FY
2023?
Total direct GHG emissions (Scope 1) metric tons
of CO2
equivalents
Data coverage (as % of denominator) percentage of:
Public Reporting
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Data Consistency
□ We are not able to report this information in absolute terms; the information provided in the table above is normalized
data. For the purpose of this question, please always provide absolute figures if available.
□ We only report on combined Scope 1 & Scope 2 emissions. Please provide the combined figures in the table above and
estion (EP Indirect Greenhouse Gas Emissions (Scope 2)).

GHG scope 1: Greenhouse gas emissions (GHGs) refer to • Greenhouse gas emissions should be reported as
emissions of the six main GHGs that are covered by the Kyoto metric tons of CO2-equivalents.
Protocol. These gases are outlined below. Each GHG has a • Data on greenhouse gas emissions should only
different capacity to cause global warming, depending on its include CO2 and all other greenhouse gas
radiative properties, its molecular weight and its lifespan in emissions.
the atmosphere. • All greenhouse gas emissions emitted directly by
the company should be reported.
Greenhouse gases covered by the Kyoto Protocol: • Greenhouse gas emissions of owned and/or
Carbon Dioxide - CO2: Emitted from the burning of fossil managed fleet must be included.
fuels, carbon dioxide accounted for some 86 percent of the • Greenhouse gas emissions due to commuting of
employees should not be included.
• Greenhouse gas emissions of business travel other
Methane - CH4: Emitted mainly from agriculture, waste than by owned and/or operated fleet should not be
disposal, leakage from the gas distribution system and coal included.
mining, methane contributed to over 6 per cent of UK
anthropogenic GHG emissions in 2003. Disclosure requirements for partially public question.
Nitrous Oxide - N2O: The main anthropogenic sources of evidence covering the following aspect of this question:
nitrous oxide emissions are agriculture, transport, industrial • Direct Greenhouse Gas Emissions (Scope 1) figure
processes, and coal combustion. Nitrous oxide accounted for for at least the most recent reported year.
approx. 6 percent of UK GHG emissions in 2003.
Third-party verification: For third-party verification, we
Hydrofluorocarbons - HFCs, Perfluorocarbons - PFCs and expect that data in the most recent year reported has been
Sulphur Hexafluoride - SF6: - third-party verified and that relevant documentation is
these are emitted mainly from air conditioning and attached showing this verification. Internal audits or
refrigeration and industrial processes. Together F-gases verification will not be considered.
accounted for around 2 percent of the UK anthropogenic GHG
emissions in 2003. Please note: In case the company has reported a value of zero
Emissions from biologically sequestered carbon: in required (e.g., comprehensive comment, internal
accordance with the GHG Protocol, emissions data for direct documentation or public reporting) to substantiate the zero
CO2 emissions from biologically sequestered carbon (e.g., reported.
CO2 from burning biomass/biofuels) must be reported
separately from the Scopes. Data consistency
• If the environmental performance data reported in
the questionnaire do not correspond to the publicly
Data Requirements
reported figures, the corresponding option should
Specific data requirements for Greenhouse gas emissions:
be marked and the discrepancy should be
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explained. This option should not be indicated if the • Environmental data of companies that are sold or
information is not publicly reported at all no longer consolidated should be excluded from
• If there is a temporary reduction in coverage due to environmental data as of the reporting period in
a corporation action, the corresponding box should which the company has not been consolidated
be marked and the reduction should be explained anymore.
• If it is not possible to report the figures in absolute • Environmental data of companies that have been
terms, the data should be reported in relative terms bought should only be included as of the reporting
and the corresponding box should be ticked. Please period in which the company is consolidated
note that information should always be reported in financially for the first time.
absolute terms if possible, even if it deviates from • Where environmental data does not cover all
public reporting. consolidated activities of the company, the
• If GHG emissions are only reported and tracked as coverage should be indicated together with the
combined Scope 1 and Scope 2 emissions, the environmental data that is known.
combined figures should be indicated in this • Indicators where a company has no
question, the corresponding box should be ticked emissions/resource use, 0 should be filled.
and the following question, EP Indirect • Where the reported environmental data deviates
Greenhouse Gas Emissions (Scope 2), should be from these definitions you are asked to explain in
marked as Not Applicable . what way the data provided differs from the
definitions.
• If a company publicly reports on long-term but not
General data requirements:
annual targets, an annual target has to be
Environmental performance data should cover the activities estimated based on internal target setting or a
of the entire company with the same consolidation as used in linear distribution.
financial reporting and must refer to the financial year (e.g., • The data must be provided in the unit indicated in
01/01 to 31/12 for both financial and environmental data) and the question. If the company is tracking the specific
be aligned with the figures reported in the Company indicator in a different unit, the unit converter must
Information section be used to convert the data into the preferred unit.
• Please ensure that the "Company Information"
Target: We require the absolute target for the most recent section has been correctly filled in, and that the
reporting year. If your company has a multiple-year and/or coverage in the table below is based on the same
relative target, please extrapolate what the target value denominator.
are progressing well towards achieving the target by the end
of the target period. If you report a combined Scope 1 + Scope
2 target, please extrapolate the share equivalent to the AASB ASRS 2 - Aus31.1(a)(i)
absolute Scope 1 emissions for inclusion in the table. CSRD - E1-3 29(b) ESRS 2 MDR-A, E1-6 44(a) AR 39, E1-6
44(d) AR 39, E1-6 48(a) AR 43, E1.IRO-1 20(a) AR 9-AR 10,
As a consequence, environmental performance data should ESRS 2 MDR-T 80j AR 24 - AR 26
only cover the direct emissions/resource use, i.e., resource EDCI - Scope 1 Emissions
use/emissions caused by the company and its consolidated ESG Disclosure Standards (China) - E.3.1.2 Scope 1 GHG
activities. Emissions and resource use of suppliers and EU Taxonomy - Multiple Objectives & Activities - Substantial
customers should be excluded. In particular, the Contribution
environmental data of group companies should follow the GISD - Scope 1 emissions
following rules: GRI Disclosure - 2-5, 305-1
• Environmental data of companies that are IRIS+ - OD4091, OI1479, OI4112, OI5732
consolidated proportionally must be considered to ISSB - IFRS S2 - 29
the proportion at which they are consolidated SASB - EM-CM-110a.1, EM-CO-110a.1, EM-EP-110a.1, EM-
financially. IS-110a.1, EM-MD-110a.1, EM-MM-110a.1, EM-RM-110a.1,
• Environmental data of companies that are fully FB-AG-110a.1, FB-FR-110b.1, FB-MP-110a.1, IF-EU-110a.1,
consolidated must be fully considered irrespective IF-WM-110a.1, RR-PP-110a.1, RT-CH-110a.1, RT-CP-110a.1,
of the proportion to which they belong to the group. TC-SC-110a.1, TR-AF-110a.1, TR-AL-110a.1, TR-CL-110a.1,
• Environmental data should refer to the specific TR-MT-110a.1, TR-RA-110a.1, TR-RO-110a.1
company structure of each particular year. There SFDR Principal Adverse Impacts - Carbon footprint, GHG
should be no pro-forma backward consolidation of Emissions, Greenhouse gas emissions
the current company structure. TCFD - Metrics & Targets b), Metrics & Targets c)
UNGC Questionnaire - E4, E6
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UNPRI - PGS 46
WEF Metrics - Greenhouse gas (GHG) emissions
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Indirect Greenhouse Gas Emissions (Scope 2)
Assessment Focus
Question Rationale
The purpose of this question is to capture the company's regulatory pressure has led to the mandatory disclosure of
indirect greenhouse gas (Scope 2) emissions and assess the certain emissions. By disclosing emissions, investors and
overall trend. Emissions can serve as a critical indicator of a stakeholders can ascertain a company's climate risks and
company's impact on the climate. Increasingly, the disclosure identify trends in emissions reduction to benchmark against
of emissions is expected from investors, and growing competitors.
Question Layout
Please provide your company's indirect greenhouse gas emissions from energy purchased (purchased and consumed, i.e. without
energy trading) (IGHG SCOPE 2) for the part of your company's operations for which you have a reliable and auditable data acquisition
and aggregation system. For each row in the table, it is mandatory that the values provided are in the same unit. Please ensure that
you have correctly filled in the Company Information section at the beginning of the questionnaire, and that the coverage in the table
below is related to the denominator relevant for your company as indicated in that section. As prescribed by the GHG Protocol, we
expect all companies to report both location-based and market-based emissions. Please refer to the information button for
additional clarifications on how to report on market-based emissions.
IGHG (Scope 2) Unit FY 2020 FY 2021 FY 2022 FY 2023 What was your
target for FY 2023?
Location-based metric tons
of CO2 equivalents
Data coverage (as % of percentage of:
denominator)
Market-based metric tons
of CO2 equivalents
Data coverage (as % of percentage of:
denominator)
Public Reporting
Data Consistency
provide an explanation in the comment box for this difference:
target to appear abnormal:
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Question-Specific Guidance & Definitions Data consistency
GHG scope 2 Indirect impacts- energy use: Many companies • If the environmental performance data reported in
report on the GHG emissions incurred in the generation of the the questionnaire do not correspond to the publicly
electricity they consume and for service companies these reported figures, the corresponding option should
indirect emissions can be more important than their direct be marked and the discrepancy should be
environmental impacts. There are also some ways that explained. This option should not be indicated if the
companies can mitigate these emissions, for example by information is not publicly reported at all.
paying a renewable tariff or improving energy efficiency. • If there is a temporary reduction in coverage due to
a corporation action, the corresponding box should
Location-based method: It reflects the average emissions be marked and the reduction should be explained
intensity of grids on which energy consumption occurs (using • If it is not possible to report the figures in absolute
mostly grid-average emission factor data). terms, the data should be reported in relative terms
Market-based method: It reflects emissions from electricity note that information should always be reported in
that companies have purposefully chosen (or their lack of absolute terms if possible, even if it deviates from
choice). It derives emission factors from contractual public reporting.
instruments, which include any type of contract between two • If GHG emissions are only reported and tracked as
parties for the sale and purchase of energy bundled combined Scope 1 and Scope 2 emissions, the
certificates or for unbundled instruments on their own. Even combined figures should be indicated in the
companies that do not purchase any market instrument are previous question (Direct Greenhouse Gas
expected to report market-based emissions. As per the GHG Emissions (Scope 1), the corresponding box should
Protocol's requirements, they shall do so by using their be ticked and this question, should be marked as
electricity supplier's emission rate, or by using the residual Not Applicable .
mix, i.e. regional emission factors representing the untracked
or unclaimed energy and emissions. If such data is not
General data requirements:
available, then their market-based emissions will be equal to
Environmental performance data should cover the activities
their location-based emissions.
of the entire company with the same consolidation as used in
financial reporting and must refer to the financial year (e.g.,
Data Requirements 01/01 to 31/12 for both financial and environmental data) and
be aligned with the figures reported in the Company
Greenhouse gas emissions should be reported as metric tons
Information section
of CO2-equivalents. Data on greenhouse gas emissions
should include CO2 and all other greenhouse gas emissions
Target: we require the absolute target for the most recent
weighted according to greenhouse gas potential.
reporting year. If your company has a multiple-year and/or
relative target, please extrapolate what the target value
Please report both your location-based emissions, as well as
your market-based emissions.
of the target period. If you report a combined Scope 1 + Scope
2 target, please extrapolate the share equivalent to the
absolute Scope 2 emissions for inclusion in the table.
• Indirect greenhouse gas emissions (scope 2) figure
Environmental performance data should only cover the
for at least the most recent reported year for at
indirect emissions/resource use, i.e., resource use/emissions
least one of the two Scope 2 reporting methods.
caused by the company and its consolidated activities.
Emissions and resource use of suppliers and customers
Third-party verification: We expect that data in the most
should be excluded. In particular, the environmental data of
recent year reported, for at least one reporting method, has
group companies should follow the following rules:
been third-party, has been third-party verified and that
• Environmental data of companies that are
relevant documentation is attached showing this verification.
consolidated proportionally must be considered to
Internal audits or verification will not be considered.
the proportion at which they are consolidated
financially.
Please note: In case the company has reported a value of zero
• Environmental data of companies that are fully
consolidated must be fully considered irrespective
required (e.g., comprehensive comment, internal
of the proportion to which they belong to the group.
documentation or public reporting) to substantiate the zero
reported.
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• Environmental data of business travel other than by • Please ensure that the Company Information
owned and/or operated fleet should not be included section has been correctly filled in, and that the
unless specifically asked for. coverage in the table below is based on the same
• Environmental data should refer to the specific denominator.
company structure of each particular year. There
should be no pro-forma backward consolidation of
the current company structure. References
• Environmental data of companies that are sold or GHG Protocol Scope 2 Guidance, An amendment to the GHG
no longer consolidated should be excluded from Protocol Corporate Standard (2015), page 59.
environmental data as of the reporting period in CDP Technical Note: Accounting of Scope 2 emissions,
which the company has not been consolidated updated in March 2022, page 20-21
anymore.
• Environmental data of companies that have been
bought should only be included as of the reporting
period in which the company is consolidated AASB ASRS 2 - Aus31.1(a)(ii), Aus31.1(e), Aus31.1(f)
financially for the first time. CSRD - E1-3 29(b) ESRS 2 MDR-A, E1-6 44(b) AR 39, E1-6
• Where environmental data does not cover all 44(d) AR 39, E1-6 49(a) AR 45, E1-6 49(b) AR 45, E1-6 52(a) AR
consolidated activities of the company, the scope 47, E1-6 52(b) AR 47, E1.IRO-1 20(a) AR 9-AR 10, ESRS 2
should be indicated together with the MDR-T 80j AR 24 - AR 26
environmental data that is known. EDCI - Scope 2 Emissions
• For indicators where a company has no ESG Disclosure Standards (China) - E.3.1.3 Scope 2 GHG
emissions/resource use, 0 should be filled. EU Taxonomy - Multiple Objectives & Activities - Substantial
• Where the reported environmental data deviates Contribution
from these definitions you are asked to explain in GISD - Scope 1, 2, and 3 emissions
what way the data provided differs from the GRI Disclosure - 2-5, 305-2
definitions. IRIS+ - OD4091, OI1479, OI5732, OI9604
• If a company publicly reports on long-term but not ISSB - IFRS S2 - 29
annual targets, an annual target has to be SASB - IF-EU-000.E
estimated based on internal target setting or a SFDR Principal Adverse Impacts - Carbon footprint, GHG
linear distribution. Emissions
• The data must be provided in the unit indicated in TCFD - Metrics & Targets b), Metrics & Targets c)
the question. If the company is tracking the specific UNGC Questionnaire - E4, E6
indicator in a different unit, the unit converter must UNPRI - PGS 46
be used to convert the data into the preferred unit. WEF Metrics - Greenhouse gas (GHG) emissions
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Indirect Greenhouse Gas Emissions (Scope 3)
Assessment Focus
Question Rationale
The purpose of this question is to capture indirect emissions measure all relevant sources of Scope 3 emissions in their
from the value chain (Scope 3 emissions) and assess the value chain to identify climate risks and opportunities,
overall trend. Scope 3 emissions represent the majority of provide transparency to the markets, and comply with
emissions for most industries, so it is crucial for companies to regulatory requirements.
Question Layout
Please provide your company's total indirect greenhouse gas emissions from your upstream and downstream value chain (IGHG Scope
3) as the sum of the 15 Scope 3 categories calculated using the GHG Protocol Corporate Value Chain Standard. Please refer to the
information button for clarification. For each row in the table, it is mandatory that the values provided are in the same unit.
IGHG (Scope 3) Unit FY 2020 FY 2021 FY 2022 FY 2023 What was your
target for FY
2023?
Total indirect GHG emissions (Scope 3) metric tons
of CO2
equivalents
Please provide your company's Scope 3 emissions split based on the 15 Scope 3 categories of the GHG Protocol Corporate Value
Chain Standard. Please use the latest available data to calculate Scope 3 emissions. Disclose any information about the methodology
used to calculate the emissions in each Scope 3 category and whether any emissions in each Scope 3 category has been excluded.
Please refer to the information button for additional clarifications and requirements. For each row in the table, it is mandatory that
the values provided are in the same unit.
Scope 3 Category Emissions in the reporting year Emissions calculation methodology
(Metric tons CO2e) and exclusions
1. Purchased Goods and Services
2. Capital Goods
3. Fuel-and-energy-related-activities (not included

in Scope 1 or 2)
4. Upstream transportation and distribution
5. Waste generated in operations
6. Business travel
7. Employee commuting
8. Upstream leased assets
9. Downstream transportation and distribution
10. Processing of sold products
11. Use of sold products
12. End of life treatment of sold products
13. Downstream leased assets
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14. Franchises
15. Investments
Other upstream
Other downstream
□ The majority of our company's revenues is generated through Royalties
Public Reporting
Data Consistency
provide an explanation in the comment box for this difference:
target to appear abnormal:

through meter readings, purchase records, utility bills,
GHG Scope 3: Scope 3 refers to indirect emissions that are a
engineering models, direct monitoring, mass balance,
consequence of the activities of the company but occur from
stoichiometry, or other methods for obtaining data from
sources not owned or controlled by the company. The GHG
Protocol divides Scope 3 emissions in 15 Scope 3 categories
that cover the upstream and downstream value chain
Secondary data: includes industry average data (e.g., from
activities of the company. Examples of upstream Scope 3
published databases, government statistics, literature
activities are the extraction and production of purchased
reviews, and industry associations), financial data, proxy
materials and transportation of purchased fuels. Examples of
data, and other generic data. In specific cases, companies
downstream activities are the use of sold products and
may use specific data from one activity in the value chain to
services and the transportation of sold goods.
estimate emissions for another activity in the value chain.
This type of data (i.e., proxy data) is considered secondary
Relevance: This refers to one of the five principles of the GHG
data, since it is not specific to the activity for which
emissions are being calculated.
Standard, which states that the scope 3 inventory should be
Source: GHG Protocol
based on the assumption that it ensures the GHG inventory
appropriately reflects the GHG emissions of the company and
-making needs both within and
Data Requirements
beyond the company. Companies should use the principle of
relevance when determining whether to exclude activities For this question, our expectations are aligned with the
from the inventory boundary. Companies should also use the guidelines of the GHG Protocol Corporate Value Chain (Scope
principle of relevance as a guide when selecting data sources. 3) Accounting and Reporting Standard. That means that we
expect companies to account for all scope 3 emissions and
According to the GHG Protocol, companies may use two types disclose and justify any exclusions (Completeness Principle
of data to calculate scope 3 emissions: primary and of the GHG Protocol Scope 3 Standard).
secondary data.
Emissions calculation methodology and exclusions: please
Primary data: includes data provided by suppliers or others provide a short description of the types and sources of data
that directly relate to specific activities in the reporting used to calculate emissions (e.g. activity data, emission
149 / 252
factors and GWP values), along with a description of the necessary that all individual Scope 3 categories are third-
methodologies, assumptions and allocation methods used. party verified to check the relevant checkbox. It is sufficient
Please also describe what has been excluded from the that the total Scope 3 value, or values for a few relevant
emissions calculation of each reported Scope 3 category (e.g. categories are third party verified.
exclusions of specific suppliers/clients, of specific business
units, countries, offices, plants, or exclusions of specific Data consistency:
types of greenhouse gases, etc.) and justify the reasons for • If the environmental performance data reported in
exclusion. the questionnaire do not correspond to the publicly
reported figures, the corresponding option should
Specific data requirements for Greenhouse gas emissions: be marked and the discrepancy should be
Greenhouse gas emissions should be reported as metric tons explained. This option should not be indicated if the
of CO2-equivalents. Data on greenhouse gas emissions information is not publicly reported at all.
should include CO2 and all other greenhouse gas emissions • If there is a temporary reduction in coverage due to
weighted according to greenhouse gas potential. a corporation action, the corresponding box should
be marked and the reduction should be explained.
All greenhouse gas emissions emitted in the upstream and • If it is not possible to report the figures in absolute
downstream value chain of the company should be reported, terms, the data should be reported in relative terms
if these are material/relevant. Companies should not exclude and the corresponding box should be ticked. Please
any activity that is expected to contribute significantly to the note that information should always be reported in
in the first table and within each Scope 3 category should be public reporting.
as complete as possible, even if considerable estimations
were needed. In the second table we expect Scope 3 General data requirements
emissions to be disclosed for at least 5 distinct categories. Environmental performance data should cover the activities
of the entire company with the same consolidation approach
Industry-Specific Guidance as used in financial reporting and must refer to the financial
• Companies in all industries are expected to disclose year (e.g., 01/01 to 31/12 for both financial and environmental
Scope 3 emissions fo data) and be aligned with the figures reported in the Company
and Services". Information section.
• Companies operating in the industry groups of
Energy (COL, OGX, OGR, GAS, PIP industries), Target: We require the absolute target for the most recent
Automobiles & Components (AUT and ATX reporting year. If your company has a multiple-year and/or
industries) and in the Homebuilding industry (HOM) relative target, please extrapolate what the target value
are expected to disclose Scope 3 emissions for would have to be for the last financial year to make sure you
• Royalty companies and other franchisors (i.e., of the target period. If you report a combined Scope 1+2+3
companies that grant licenses to other entities to target, please extrapolate the share equivalent to the
sell or distribute its goods or services in return for absolute Scope 3 emissions for inclusion in the table.
payments) are expected to account for emissions
that occur from the operation of franchises (i.e., the Environmental performance data should cover the emissions
scope 1 and 2 emissions of franchisees) in Scope 3 of suppliers and customers, and of other entities in the
category 14: Franchises. upstream and downstream value chain (e.g. franchisees,
lessees and lessors, third-party logistics providers, retailers,
Disclosure requirements for partially public question etc.). In particular, the environmental data of group
Additional credit will be granted for relevant publicly available companies should follow the following rules:
• Indirect greenhouse gas emissions (Scope 3) figure • Environmental data of companies that are
for either the most recent reported year or the most consolidated proportionally must be considered to
recent reported year -1, or of at least one individual the proportion at which they are consolidated
Scope 3 category with value different from 0. financially.
• Environmental data of companies that are fully
Third-party verification: We expect that data in the most consolidated must be fully considered irrespective
recent reported year or the most recent year -1 has been of the proportion to which they belong to the group.
third-party verified and that relevant documentation is • Environmental data should refer to the specific
attached showing this verification. Internal audits or company structure of each particular year. There
verification will not be considered. Please note that it is not
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should be no pro-forma backward consolidation of This question contains categories of Scope 3 emissions and
the current company structure. defini
• Environmental data of companies that are sold or Chain (Scope 3) Accounting and Reporting Standard,
no longer consolidated should be excluded from published in September 2011.
environmental data as of the reporting period in
which the company has not been consolidated Standards & Frameworks
anymore.
• Environmental data of companies that have been AASB ASRS 2 - Aus31.1(a)(iii), Aus31.1(b)(ii)(2), Aus31.1(g)(i),
bought should only be included as of the reporting Aus31.1(g)(ii)
period in which the company is consolidated CSRD - E1-3 29(b) ESRS 2 MDR-A, E1-6 44(c) AR 39, E1-6
financially for the first time. 44(d) AR 39, E1-6 51 AR 46, E1-6 AR 46h, E1-6 AR 46i, E1.IRO-
• Indicators, where a company has not calculated 1 20(a) AR 9-AR 10, ESRS 2 MDR-T 80j AR 24 - AR 26
emissions, should be left blank. Zeros should be EDCI - Scope 3 Emissions (tCO2e) (optional)
entered only when the company has calculated its ESG Disclosure Standards (China) - E.3.1.1 Sources and types
emissions and their emissions are zero. of greenhouse gases, E.3.1.4 Scope 3 GHG
• Where the reported environmental data deviates GISD - Automobiles & Components: Greenhouse gas
from these definitions you are asked to explain in emissions intensity by vehicle distance traveled, Scope 3
what way the data provided differs from the emissions
definitions. GRI Disclosure - 2-5, 305-3
• If a company publicly reports on long-term but not IRIS+ - OD4091, OI1479, OI5732, PD9427
annual targets, an annual target has to be ISSB - IFRS S2 - 29
estimated based on internal target setting or a SASB - TR-AF-430a.2
linear distribution. TCFD - Metrics & Targets b), Metrics & Targets c)
• The data must be provided in the unit indicated in UNGC Questionnaire - E4, E7, E7.1
the question. UNPRI - PGS 46
WEF Metrics - Greenhouse gas (GHG) emissions
References
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Climate Governance
Assessment Focus
Question Rationale
The purpose of this question is to assess whether a certain roles or committees, as well as the frequency of
discussions on climate issues.
responsibility for the oversight and management of climate
risks and opportunities. This information helps investors and This question is aligned with TCFD which recommends
other stakeholders understand whether climate-related
issues receive sufficient attention at the highest levels of climate-
governance. This can be indicated by public disclosure of assessing and managing climate-related issues.
board oversight and management responsibility assigned to
Question Layout
Does the carry oversight and management responsibility of climate-
related issues and is this information available publicly?
□ Yes, board of directors and/or executive management has oversight and management responsibility of climate-
related issues. Please indicate where this information is available in public reporting or corporate website.
Board Oversight
□ Yes, there is a board level committee with oversight of climate-related issues
Please select the committee from the drop-down list

▪ Climate/Sustainability/ESG Committee
▪ Risk Committee
▪ Audit Committee
▪ Other committee with clear oversight on climate-related issues
□ There is no board level committee with oversight of climate-related issues

□ Climate issues are on the agenda of the board of directors. Please specify the frequency with which climate-related issues
are scheduled agenda items
□ At least annually
□ Less frequent than annually, or not specified
Management Responsibility
□ Yes, there is a management position or committee with responsibility for climate-related issues.
Please select the appropriate option from the drop-down list.

▪ Chief Climate/Sustainability/ESG Officer
▪ Executive level climate or sustainability-specific committee
▪ Chief Risk Officer or another C-suite executive with climate responsibility (not CEO)
▪ Another committee with clear responsibility for management of climate-related issues
▪ Below C-suite management position with clear responsibility for management of climate-related issues
o There is no management position or committee with responsibility for climate-related issues.
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Question-Specific Guidance & Definitions For two-tier boards, the board-level committee must be
formed of members of the supervisory board.
Board-level committee with oversight: Assigned committee,
formed of board members only, with responsibility for
Management responsibility: Management responsibility
overseeing climate-related issues.
refers to the highest level of management with dedicated
responsibility for managing climate-related issues. This can
Management position: Highest ranking individual with
either be an individual or a management-level committee. The
dedicated management responsibility for assessing and
individual or committee should not be part of the board of
managing climate-related issues.
directors. Please select the correct option from the drop-
down list.
Management-level committee: A management-level
committee responsible for assessing and managing climate-
If you have both a Chief Climate/Sustainability/ESG Officer
related issues.
and a Chief Risk Officer who manage climate-related risks,
please select Chief Climate/Sustainability/ESG Officer.
Data Requirements
Board Oversight: Board oversight refers to a board-level For two-tier boards, management responsibility can be at the
committee responsible for overseeing climate-related issues. management board level.
Evidence that the committee oversees climate-related issues

should be available in the relevant section in TCFD, CDP or This question requires supporting evidence from the public
other reports. Please select the correct option from the drop- domain. The information provided has to be included in your
down list. public reporting (e.g. annual report, sustainability report,

If the board committee is different from a climate or website.
sustainability-specific committee, the climate responsibility

needs to be clearly described within public reporting.
In order to accept the committee as a board-level committee, AASB ASRS 1 - 25(a), 27(a), 27(a)(iii), 27(b)(i)
all members must be part of the board. If the committee is ESG Disclosure Standards (China) - G.3.3.1 Integrate ESG into
made up of both board members and management, please corporate strategy
GRI Disclosure - 11.2, 12.2
section of the question. ISSB - IFRS S2 - 6
TCFD - Governance a), Governance b)
UNGC Questionnaire - E1.1
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TCFD Disclosure
Assessment Focus
Question Rationale
This question focuses on whether a company applies the Directive 2014/95/EU, which embeds regulatory guidance
TCFD framework in the management of climate-related risks based on the TCFD recommendations. Many national
and opportunities. Demand for climate-related disclosure governments and public sector organizations formally
from investors has increased significantly since the release of support the TCFD and some have started to issue regulation
the TCFD recommendations in 2017. In addition, public sector making TCFD disclosure mandatory.
leaders have also noted the importance of transparency on
climate-related issues within financial markets. Climate- Delay in applying the TCFD framework can not only result in
related risk is increasingly the subject of new reporting
requirements, such as the European Non-financial Reporting
Question Layout
Does the company apply the TCFD framework in the management of climate-related risks and opportunities and is it available
publicly?
□ Yes, the company integrates the TCFD framework or are in the process of integrating it and publicly address the following
requirements: Please indicate where this information is available in public reporting or corporate website.
Governance
□
□ te-related risks and opportunities.
Strategy
□ a) Describe the climate-related risks and opportunities the organization has identified over the short, medium, and
long term.
□ b) Describe the impact of climate-related risks and opportunities on the organizati
financial planning.
□ c) Describe the resilience of the organiz -related scenarios,
including a 2°C or lower scenario.
Risk Management
□ a) Describe the organiz -related risks.
b) Describe the organiz -related risks.
□ c) Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the
organiz
Metrics & Targets

□ a) Disclose the metrics used by the organization to assess climate-related risks and opportunities in line with its
strategy and risk management process.
□ b) Disclose Scope 1, Scope 2, and if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks.
□ c) Describe the targets used by the organization to manage climate-related risks and opportunities and performance
against targets.
□ The company publicly commits to integrate the TCFD framework, but it does not yet report on any of the requirements. Please
indicate the timeframe when you plan to disclose the requirements:
□ No, the company does not apply the TCFD framework in its risk management. Please explain the reason.
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Data Requirements ISSB - IFRS S2 - 10, IFRS S2 - 15, IFRS S2 - 22, IFRS S2 - 25,
IFRS S2 - 6
This question requires public evidence. Please indicate where
SASB - FN-IN-450a.3
in your public reporting you report information about applying
TCFD - Governance a), Governance b) , Metrics & Targets a),
the TCFD framework.
Metrics & Targets b), Metrics & Targets c), Risk Management
Standards & frameworks a), Risk Management b), Risk Management c), Strategy a),
AASB ASRS 1 - 25(a), 25(b), 25(c), 25(d), 27(a), 27(b)(i), 29(a), Strategy b), Strategy c)
29(c), 30(a), 30(b), 33, 44(b), 44(c), 46(b)(i), 46(b)(ii) UNGC Questionnaire - G12
AASB ASRS 2 - 22(b)(i)(1), Aus10.1, Aus9.1(a) UNPRI - PGS 17
CSRD - E1.SBM-3 19(b) AR 7a, ESRS 2 BP-2 15, ESRS 2 GOV-1 WEF Metrics - TCFD implementation
22a AR 3, ESRS 2 GOV-1 22c AR 3, ESRS 2 MDR-M 77c

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Climate-Related Management Incentives
Assessment Focus
Question Rationale
This question aims to capture how rewards are associated This ensures that climate-related ambitions and goals are
with the management of climate change issues, including embedded throughout the company and that management is
attainment of targets. held accountable for the achievement of these goals.
Question Layout
Does your company provide incentives for the management of climate change issues, including the attainment of targets?
Please indicate where this information is available in your public reporting or corporate website .
□ Yes, we provide details on the climate change-related incentives starting from the highest management level and the
information is publicly available.
Who is entitled to benefit from this incentive? Type of incentive Incentivized KPIs
Select each option only once Please provide a description of the KPI
and how it is incentivized
Drop-down menu: Drop-down menu: Drop-down menu:
Chief Executive Officer (CEO) Monetary Emissions reduction

Other Named Executives Officers Recognition (non-monetary) Energy reduction
Business Unit Managers Other Efficiency
Employees Purchasing
Other, please specify _____ Supply chain engagement
Other, please specify_____
2. 2. 2.
3. 3. 3.
Question Specific Guidance & Definitions Data Requirements

Incentives: Please note that incentives can be positive (i.e. If several types of incentives are used in your company,
giving access to something) or negative (preventing access to please select the incentive that is most commonly employed
something). Examples of incentive types include: and include the fact that your company also uses other
• Monetary: a bonus or some form of financial incentives in the comment box.
remuneration.
• Recognition (non-monetary): employee award (e.g. Each employee group should only be selected once.
employee of the year) or career progression scheme,
but not tied directly to any form of financial When you select an incentive for a certain employee group, it
remuneration. is not necessary for all employees in this group to be entitled
• Other non-monetary rewards: including increased to benefit from this incentive. For example, you can select the
holiday allowances, special assignment, etc. category "Business Unit Managers" even if only one manager
is entitled to the incentive.
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included in your public reporting (e.g. annual report, ESG Disclosure Standards (China) - G.2.5.3 Linkage between
sustainability report, integrated report, company executive performance and ESG goals
publications, separate fuel efficiency strategy GRI Disclosure - 11.2, 12.2
document) or corporate website. IRIS+ - OI4953
• Any response that cannot be verified in the attached ISSB - IFRS S2 - 29, IFRS S2 - 6
public document(s) will not be accepted. TCFD - Metrics & Targets a)
UNGC Questionnaire - G10
AASB ASRS 1 - 27(a)(v)
AASB ASRS 2 - 29(g)(i)
CSRD - E1-1 14 AR 1, E1.GOV-3 13, ESRS 2 GOV-3 29b AR 7
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Climate Risk Management
Assessment Focus
Question Rationale
The purpose of this question is to assess whether your
company has a climate risk management process that is, a climate-related risks, and on how processes for identifying,
process for identifying, assessing, and responding to climate- assessing, and managing climate-related risks are integrated
related risks. Although nearly all organizations are affected
by climate change-related risks, the most significant effects
of climate change are likely to emerge over the medium to This question is also aligned with the European Non-financial
longer term, while the precise timing and magnitude of these Reporting Directive 2014/95/EU, which demands that when
impacts remain uncertain. Climate risk assessments covering reporting on their climate-related risks and opportunities,
different climate risk types, different value chain stages and companies consider their whole value chain. Risks of negative
time-horizons can be helpful to understand the potential impacts on an organization and risks of negative impacts on
strategies, and financial performance. may also occur throughout the value chain, both upstream in
the supply chain and downstream.
This question is aligned with the TCFD Risk Management
recommendations which include recommended disclosures
Question Layout
Does the company have a Climate Risk Management process and is it available publicly?
□ Yes, the company has a climate risk management process. Please indicate where this information is available in public reporting
or corporate website.
Climate Risk Management
□ Integrated into multi-disciplinary company-wide risk management processes, i.e. a documented process where climate
all types/sources of risks and opportunities

□ A specific climate change risk management process, i.e. a documented process which considers climate change risks and
opportunities separate from other business risks and opportunities
Types of climate-related risk included in risk assessment
□ Current Regulation
□ Emerging Regulation
□ Technology Risk
□ Legal Risk
□ Market Risk
□ Reputational Risk
□ Acute Physical Risk
□ Chronic Physical Risk
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Value chain stages covered by climate risk assessment
□ The assessment includes our own operations

□ The assessment includes our upstream activities
□ The assessment includes our downstream activities and/ or clients
Time horizon(s) covered by climate risk assessment
□ Short-term
□ Medium-term
□ Long-term
Question Specific Guidance & Definitions reduce GHG emissions, shifting energy use toward
lower-emission sources, and adopting energy-
Risk Assessment: Systematic process for an organization to
efficiency solutions. The risk associated and
evaluate potential risks that may impact its assets and
financial impact of policy changes depend on the
operations.
nature and timing of the policy change. Another
important risk is litigation risk, which can occur as a
(TCFD (2017), Recommendations of the Task Force on
result of litigation by for example property owners,
Climate-related Financial Disclosures)
municipalities, states, insurers, shareholders, and
public interest organizations.
Physical risks: Physical risks resulting from climate change
• Current regulations include current laws and
can be event driven (acute) or longer-term shifts (chronic) in
regulation related to carbon pricing mechanisms,
climate patterns. Physical risks may have financial
emissions reporting, existing products and services,
implications for organizations, such as direct damage to
the supervision of climate risks in the financial
assets and indirect impacts from supply chain disruption.
sector (Financial services only)
e affected by
• Emerging regulations include emerging laws and
changes in water availability, sourcing, and quality; food
regulation related to carbon pricing mechanisms,
security; and extreme temperature changes affecting
emissions reporting, existing products and services,
the supervision of climate risks in the financial
needs, and employee safety.
sector (Financial services only)
• Acute physical risks refer to those that are event-
• Technological risks result from technological
driven, including increased severity of extreme
improvements or innovations that support the
weather events, such as cyclones, hurricanes, or
transition to a lower-carbon, energy-efficient
floods.
economy. For example, the development and use of
• Chronic physical risks refer to longer-term shifts in
emerging technologies such as renewable energy,
climate patterns (e.g., sustained higher
battery storage, energy efficiency, and carbon
temperatures) that may cause sea level rise or
capture and storage will affect the competitiveness
chronic heat waves.
of certain organizations, their production and
distribution costs, and ultimately the demand for
TCFD (2017)
their products and services from end-users.
https://www.tcfdhub.org/Downloads/pdfs/E06%20-
• Market risks can impact companies in various ways.
%20Climate%20related%20risks%20and%20opportunities.p
One of the major ways is through shifts in supply
df
and demand for certain commodities, products, and
services.
Transition risks: Transitioning to a lower-carbon economy
• Reputational risks may arise from changing
may entail extensive policy, legal, technology, and market
customer or community perceptions of an
changes to address mitigation and adaptation requirements
related to climate change. Depending on the nature, speed,
transition to a lower-carbon economy.
and focus of these changes, transition risks may pose varying
levels of financial and reputational risk to organizations.
TCFD (2017), Technical Supplement: The Use of Scenario
Transition risks can be divided into four categories: policy and
Analysis in Disclosure of Climate-related Risks and
regulatory risks, technological risks, market risks, and
Opportunities)
reputational risks.
Value Chain: Terminology used to describe the upstream and

• Policy, regulation, and legal risks include
downstream life cycle of a product, process, or service,
implementing carbon-pricing mechanisms to
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including material sourcing, production, consumption, and
disposal/recycling. Supporting evidence:
• Upstream activities include operations that relate your response.
to the initial stages of producing a good or service, • The supporting documents must be available in the
e.g. material sourcing, material processing, and public domain.
supplier activities. • Any response that cannot be verified in the attached
• Own operations include operations related to the document(s) will not be accepted
direct stages of producing a good or service, such as
manufacturing or processing the materials into a
References
finished product.
TCFD (2017), Technical Supplement: The Use of Scenario
• Downstream activities include operations that
Analysis in Disclosure of Climate-related Risks and
relate to processing the materials into a finished Opportunities
product, delivering it to the end user, and the
https://www.fsb-tcfd.org/publications/final-technical-
customer use phase (e.g. transportation, supplement/
distribution and consumption).
CDP (2017), CDP Technical Note on Scenario Analysis
Conducting and disclosing scenario analysis
(TCFD (2017), Technical Supplement: The Use of Scenario
EU, Technical Expert Group (TEG)(2020) Technical Annex on
Analysis in Disclosure of Climate-related Risks and technical screening criteria for economic activities that can
Opportunities) make a substantial contribution to climate change mitigation
or adaptation. https://finance.ec.europa.eu/sustainable-
finance/tools-and-standards/eu-taxonomy-sustainable-
Time Horizon: Terminology used to describe what your activities_en
organisation considers to be short-, medium- and long-term
European Commission, Guidelines on reporting climate-
horizons (from year to year) considering the expected lifetime
related
of the assets or activities. information https://ec.europa.eu/finance/docs/policy/19061
8-climate-related-information-reporting-guidelines_en.pdf
Data Requirements
For the first part of the question, please select the option that Standards & frameworks
best describes the risk management procedures with regard
AASB ASRS 1 - 25(b), 31, 44(a)(i), 44(c)
to climate change risks and opportunities.
AASB ASRS 2 - 22(b)(i)(6), 22(b)(i)(7), Aus10.2
CSRD - E1-1 14 AR 1, E1.IRO-1 20(b)i AR 11, AR 13-AR 14,
If you have more than one climate risk management process
E1.IRO-1 21 AR 13-AR 14, E1.IRO-1 AR 11a, AR 13-AR 14,
in place in your organization, please select the one that is
E1.IRO-1 AR 12a, AR 13-AR 14, E1.SBM-3 18, ESRS 2 IRO-1
most commonly employed.
53e, ESRS 2 IRO-1 53f, ESRS 2 SBM-3 48f
ESG Disclosure Standards (China) - G.2.2.4 Climate risk
Please include in your response which types of physical and
identification and prevention
transition risks are considered in your risk assessment, along
EU Taxonomy - Appendix A - Climate Change Adaptation
with the value chain stages covered and the time horizons
IRIS+ - OI2092
considered.
ISSB - IFRS S2 - 10, IFRS S2 - 22, IFRS S2 - 25
SASB - EM-EP-530a.1, EM-RM-530a.1, EM-SV-530a.1, IF-
Value chain stages considered may differ depending on which
RE-450a.2, RR-FM-450a.1, RR-ST-410a.2, RT-CH-530a.1
types of physical and transition risks are considered. Please
TCFD - Risk Management a), Risk Management c), Strategy a)
select all the value stages considered and time horizons
WEF Metrics - Integrating risk and opportunity into business
included if they were used to assess at least one of the
process
physical or transition risk types selected. Time horizons must
be available for at least one of the physical or transition risk
types selected.
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Financial Risks of Climate Change
Assessment Focus
Question Rationale
With this question we aim to find out if companies have substantive changes in business operations, revenue or
identified the risks where there is the potential for expenditure to arise.
Question Layout
Have you identified any climate change risks (current or future) that have potential to generate a substantive change in your business
operations, revenue or expenditures?
□ Yes, we have identified climate change-related risks with potential impact. Please estimate the financial impact for the most
significant risk from each category and provide supporting evidence:
Risks driven by changes in regulation:
Currency:
□ Information is available publicly for the description and estimated financial implications of the risk
□ Brief description of the most significant risk and methods used to manage this risk:
□ Estimated financial implications of the risk before taking action:
Average estimated time frame (in number of years) for financial implications of this risk:
□ Estimated costs of these actions:
Risks driven by change in physical climate parameters or other climate-change related developments
Currency:
□ Information is available publicly for the description and estimated financial implications of the risk:
□ Brief description of the most significant risk and methods used to manage this risk:
□ Estimated financial implications of the risk before taking action:
Average estimated time frame (in number of years) for financial implications of this risk:
□ Estimated costs of these actions:
□ We have conducted an analysis of our climate change risk, but our company is not exposed to climate change risks that have the
potential to generate a substantive change in business operations, revenue, or expenditure. Please specify:

Climate change risks: can include, but are not limited to: • Already managed and therefore not expected to
• Currently being experienced or expected to arise in the generate negative residual impacts (e.g. because of an
future insurance policy)
• Newly identified
• Risks which cannot be managed
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• Well understood or with high levels of uncertainty with Please describe and provide figures concerning the most
regard to the likelihood of the risk materializing and the significant risk from each category (i.e. the risk which has the
extent to which it will impact the business most potential to generate a substantive change in your
business operations, revenue or expenditure). Please provide
Regulatory risks: arise from current and/or expected city, quantification of climate change risks for those parts of the
state, regional, national or global governmental policy related business where such analysis has been conducted. If this
to climate change. Risks include, but are not limited to, the assessment does not cover all business operations, please
imposition of emissions limits, energy efficiency standards provide data for those measured areas only and provide an
and carbon trading schemes. explanation of which areas are covered in the comment box.
Physical risks: may arise from dramatic extreme weather

events or subtle changes in weather patterns.
Disclosure requirements for partially public question:
Other climate-related risks: include, but are not limited to: Additional credit will be granted for relevant publicly available
reputation, changing consumer behavior, induced changes in evidence for the following:
human and cultural environments, fluctuating socio-
economic conditions and increasing humanitarian demands. • Description of risks driven by changes in regulation
• Description of risks driven by changes in physical
Under financial implications: you are asked to provide climate parameters or other climate-change related
quantitative estimates of the inherent financial impacts of developments
the risks before taking into consideration any controls you • Estimated financial implication of the risk(s)
may have in place to mitigate the impacts. An example would
be the cost of destruction of facilities from extreme weather Supporting evidence:
before taking into consideration how much insurance • The document(s) you attached will be used to verify
coverage you have. It is acknowledged that these will be the qualitative part of your response. If a question
estimates. text field is available, a comprehensive answer in
that field can be accepted instead of a supporting
The methods: you are using or plan to use to manage the risk document. Any qualitative response that cannot be
could include diversification of product/service offering, verified in the attached document(s) or via the
research and development in new product lines or lobbying of information provided in the related question text
decision makers. In all cases please identify how this action field (if available) will not be accepted.
has affected (or is expected to affect) the likelihood and/or • Quantitative figures provided in the response do not
magnitude of the risk (i.e. the residual risk) and over what need supporting evidence. You may still provide a
timeframe the risk is expected to or has been reduced. reference using the reference clip. This could
The costs associated: with the management actions you have approaches to data aggregation used to compile the
described can be annual or capital costs. Where there is no provided quantitative information.
additional cost for action, please explicitly state this is the
case. Where the cost is integrated into existing budgets, Standards & frameworks
please provide some estimate of the scale of those costs.
AASB ASRS 1 - 17, 18, 29(a), 29(b), 30(a)
Timeframe: the time frame refers to the time when you expect AASB ASRS 2 - 14(a)(i), 29(e), Aus9.1(a), Aus9.1(b)
the risks are likely to materialize. It is acknowledged that CSRD - E1.IRO-1 20(b)ii AR 13-AR 14, E1.IRO-1 20(c)ii AR 13-
risks further into the future are likely to have a higher degree AR 14, E1.IRO-1 21 AR 13-AR 14, ESRS 2 SBM-3 48c AR 17
of uncertainty associated with them. ESG Disclosure Standards (China) - G.2.2.4 Climate risk
identification and prevention
For companies submitting to CDP: please use the average GRI Disclosure - 201-2
between the two numbers of the time frame range. E.g. if the ISSB - IFRS S2 - 10, IFRS S2 - 13, IFRS S2 - 14, IFRS S2 - 15,
estimated time frame for financial implications of this risk is IFRS S2 - 29

TCFD - Strategy a), Strategy b)
the estimated time frame field. WEF Metrics - Integrating risk and opportunity into business
process
Data Requirements
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Financial Opportunities Arising from Climate Change
Assessment Focus
Question Rationale can represent additional costs, others (or even the same
changes) represent opportunities to exploit new markets or
When a company faces risks associated with climate change products. This question aims to find out if companies have
(reported in previous question) it is possible that they may identified climate change related opportunities that have the
also experience opportunities. Both arise from changes in the potential to generate positive change in their business
operating environment of a company and as some changes operations, revenue generation and expenditure.
Question Layout
Have you identified any climate change-related opportunities (current or future) that have the potential to generate a substantive
positive change in your business operations, revenue, expenditure (i.e. opportunities driven by changes in regulation, physical, or
other climate change-related developments)?
□ Yes, we have identified climate change-related opportunities. Please briefly describe the most significant opportunity resulting
from climate change on your business operations, revenue growth, or expenditures and provide supporting evidence:
Currency:
□ Information is available publicly for the description and estimated financial implication of the opportunity:
□ Please provide description below:
□ Please estimate the annual financial positive implications of this opportunity:
Estimated time frame (in number of years) for positive financial implications of this opportunity:
□ Please estimate the current annual costs associated with developing this opportunity:
□ We do not consider climate change related opportunities (current or future) to be relevant to our business, please explain why:

Climate Change Opportunities: can include, but are not its customers to meet mandatory requirements or those
limited to:
companies who provide services assisting others in meeting
• Currently being experienced or expected to arise in the regulatory requirements. Regulation may also create new
future markets such as emission trading markets leading to new
• Being managed or newly identified opportunities.
• Well understood or with high levels of uncertainty with
regard to the likelihood of the opportunity materializing Physical changes: related to climate change may present
and the extent to which it will impact the business opportunities in a variety of ways. Reduced sea ice may allow
access to new areas for vessels. Changing temperature and
Opportunities can be related to any of the following rainfall may extend growing seasons for farmers.
categories: Alternatively, your organization may have goods and services
that enable others to adapt to physical changes.
Regulation: on climate change related issues may present
opportunities for your organization if it is better suited than Other climate-related opportunities: include those posed by
its competitors to meet those regulations, or more able to changes in consumer attitude or improved standing due to
help others to do so. Possible scenarios would include a
company whose products already meet anticipated standards
designed to curb emissions, those whose products will enable
163 / 252
The financial implications: of the opportunity should be • Description of relevant financial opportunities
expressed quantitatively. It is acknowledged that these will arising from climate change
be estimates and where possible the assumptions made in • Estimated financial implication and estimated cost
arriving at a financial impact figure should be stated in the
comment box.
The costs associated: with developing the opportunities refer
to the cost arising from the actions needed to exploit the
the qualitative part of your response. If a question
opportunity and maximize its potential realization. Where
text field is available, a comprehensive answer in
there is no cost for action, please explicitly state this in the
that field can be accepted instead of a supporting
document. Any qualitative response that cannot be
provided.
verified in the attached document(s) or via the
information provided in the related question text
Time frame: - the timeframe refers to the time when you
field (if available) will not be accepted.
expect the opportunities to materialize. It is acknowledged
• Quantitative figures provided in the response do not
that opportunities further into the future are likely to have a
need supporting evidence. You may still provide a
higher degree of uncertainty associated with them.
reference using the reference clip. This could
For companies submitting to CDP: please use the average
approaches to data aggregation used to compile the
between the two numbers of the time frame range. E.g. if the
estimated time frame for positive financial implications of
((4+8)/2 = 6) in the estimated time frame field. Standards & frameworks

AASB ASRS 1 - 17, 18, 29(a), 29(b), 30(a)
Data Requirements AASB ASRS 2 - 14(a)(i), 29(e), Aus9.1(a), Aus9.1(b)

CSRD - E1.IRO-1 20(c)ii AR 13-AR 14, E1.IRO-1 21 AR 13-AR
Please describe and provide figures concerning the most 14, E3-5 33a AR 34, E3-5 33b, E3-5 33c, ESRS 2 SBM-3 48c
significant opportunity identified. AR 17
ISSB - IFRS S2 - 10, IFRS S2 - 13, IFRS S2 - 14, IFRS S2 - 15,
IFRS S2 - 21, IFRS S2 - 29
TCFD - Strategy a), Strategy b)
Disclosure requirements for partially public question: WEF Metrics - Integrating risk and opportunity into business
Additional credit will be granted for relevant publicly available process
evidence for the following:
164 / 252
Climate-Related Scenario Analysis
Assessment Focus
Question Rationale
Companies need to consider a broad range of assumptions,
uncertainties, and potential effects of climate change on their This question is aligned with the TCFD recommendations,
businesses, strategies, and financial performance across which include a recommended disclosure on the resilience of
different time horizons and different temperature pathways.
One way to do this is through conducting climate-related different climate-related scenarios, including a 2°C or lower
scenario analysis. scenario.
Question Layout
Does the company conduct climate-related scenario analysis and is this information available publicly?
□ Yes, the company conducts climate-related scenario analysis. Please indicate where this information is available in public
reporting or corporate website.
□ We use qualitative climate-related scenario analysis
□ We use quantitative climate-related scenario analysis
□ We use qualitative and quantitative climate-related scenario analysis
Please select any climate-related scenarios your organization has used in their climate -related scenario analysis
Scenario Type 2°C or below 2°C Above 2°C
Transition Scenario □ IEA NZE 2050 □ IEA STEPS (previously IEA

□ IEA 2DS NPS)
□ IEA B2DS □ IEA CPS
□ IEA 450 □ NGFS (Above 2°C scenarios)
□ IEA SDS
□ IEA APS or Nationally determined contributions
(NDCs)
□ Greenpeace
□ DDP
□ IRENA
□ BNEF NEO
□ NGFS (2°C and below scenarios)
Physical Scenario □ RCP 1.9 (or SSP1 1.9) □ RCP 3.4 (or SSP4 3.4)
□ RCP 2.6 (or SSP1 2.6) □ RCP 4.5 (or SSP2 4.5)
□ RCP 6.0 (or SSP4 6.0)
□ RCP 7.0 (or SSP3 7.0)
□ RCP 8.5 (or SSP5 8.5)
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□ Our analysis covers at least one 2°C or below 2°C scenario that is not listed in the table, please provide further details.
□ Our analysis covers at least one above 2°C scenario that is not listed in the table, please provide further details.
Question Specific Guidance & Definitions -

to replace Representative Concentration Pathways (RCPs)
Scenario Analysis: Process for identifying and assessing a
although RCPs still form the basis of SSPs and are widely
potential range of outcomes of future events under conditions
used.
of uncertainty. In the case of climate change, for example,
scenarios allow an organization to explore and develop an
https://www.ipcc.ch/assessment-report/ar6/
understanding of how the physical and transition risks of
climate change may impact its businesses, strategies, and
International Energy Agency (IEA): The IEA produces various
financial performance over time. Climate-related scenario
energy and transition risk-related scenarios, details of which
analysis should consider climate risks that are material to
can be used for transition risk scenario analysis.
companies' operations and value chain.
https://www.iea.org/reports/global-energy-and-climate-
(TCFD (2017), Recommendations of the Task Force on
model
Climate-related Financial Disclosures)
Other listed transition scenarios:

Qualitative scenario analysis explores relationships and
trends for which little or no numerical data is available. This is
• Network for Greening the Financial System (NGFS):
generally a high-level, narrative approach to scenario
https://www.ngfs.net/ngfs-scenarios-portal/
analysis, suitable for organizations that are familiarizing
• Greenpeace: https://www.greenpeace.org/usa/wp-
themselves with the process. For example, relying on industry
content/uploads/legacy/Global/usa/report/2009/4/
trends and applying them to a specific organization or
energy-r-evolution-a-sustain.pdf
business activity, or undertaking quantitative research into a
• Deep Decarbonization Pathways (DDP):
specific trend.
https://ddpinitiative.org/display/
• International Renewable Energy Agency (IRENA):
Quantitative scenario analysis assesses measurable trends
https://www.irena.org/publications/2020/Sep/Scen
and relationships using quantitative models, data sets and
arios-for-the-Energy-Transition-Global-experience-
other analytical techniques to illustrate potential pathways or
and-best-practices
outcomes. This is a more detailed approach to conducting
• BloombergNEF New Energy Outlook (BNEF NEO):
scenario analysis. External, third-party scenarios or data sets
https://about.bnef.com/new-energy-outlook/
can be used, or companies can develop in-house modeling
capabilities considering specific assumptions or parameters.
Data Requirements
2°C or below 2°C, and above 2°C: Under the 2015 Paris
Please select all the climate scenarios you have used to
Agreement, nearly 200 countries agreed to limit global
assess physical and transition risks. In line with the TCFD
warming to no more than 2 degrees Celsius by 2100, and to
recommended disclosure, at least two scenarios are required
aim for a no more than 1.5 degrees Celsius increase. The 2-
for full scoring. One of these scenarios should be a 2 °C or
lower scenario, the other should be an above 2 °C scenario.
accepted limitation of temperature growth to avoid
significant and potentially catastrophic changes to the
If your company conducts climate scenario analysis with
planet. 2-degree or below scenarios can also be referred to as
scenarios that are not listed in the question table, please
describe the following elements in the text box below the
potential situation where this agreement is not met.
selected option. Please note that this information should be
available in the public domain.
https://www.spglobal.com/en/research-
insights/articles/what-s-the-deal-with-the-2-degree-
• A description of the scenarios used, and whether
scenario
the scenarios used are 2°C or lower scenarios or
above 2°C scenarios.
IPCC RCP/SSP: The United Nations Intergovernmental Panel
Please note: for companies which use NGFS scenarios for
on Climate Change (IPCC) produces physical risk scenarios
under a variety of warming pathways. Within its sixth-
analysis covers atleast one [
assessment report (AR6), new scenarios were developed
option depending on the temperature used.
166 / 252
Supporting evidence: https://ec.europa.eu/finance/docs/policy/190618-climate-
• The document(s) you attached will be used to verify related-information-reporting-guidelines_en.pdf
your response.
• The supporting documents must be available in the
public domain.
• Any response that cannot be verified in the attached AASB ASRS 1 - 44(a)(iii)
document(s) will not be accepted AASB ASRS 2 - 22(b)(i)(1), 22(b)(i)(2), 22(b)(i)(3), 22(b)(i)(4),
Aus22.1
CSRD - E1-1 14 AR 1, E1-4 AR 30c, E1.IRO-1 20(b)i AR 13-AR
References
14, E1.IRO-1 20(c)i AR 13-AR 14, E1.IRO-1 21 AR 13-AR 14,
TCFD (2017), Technical Supplement: The Use of Scenario E1.IRO-1 AR 11d, AR 13-AR 14, E1.IRO-1 AR 12c, AR 13-AR 14,
Analysis in Disclosure of Climate-related Risks and E1.SBM-3 19(b) AR 7b, ESRS 2 SBM-3 48f
Opportunities EU Taxonomy - Appendix A - Climate Change Adaptation
https://www.fsb-tcfd.org/publications/final-technical- ISSB - IFRS S2 - 22, IFRS S2 - 25
supplement/ SASB - IF-HB-420a.2
CDP (2017), CDP Technical Note on Scenario Analysis TCFD - Strategy a), Strategy b), Strategy c)
Conducting and disclosing scenario analysis UNGC Questionnaire - G6
related information
167 / 252
Physical Climate Risk Adaptation
Assessment Focus
Question Rationale
The climate risk assessment of physical and transition risks Climate change mitigation and adaptation is a central part of
builds the basis for companies to plan adaptation and the EU taxonomy for sustainable activities. The information
mitigation measures in response to those risks. Adaptation on risk assessment of physical impacts is required for
and mitigation measures are ideally planned so that context evaluating compliance with the EU Taxonomy Do No
specific factors are considered for all relevant assets and Significant Harm criteria on climate change adaptation. The
operations, since climate-related hazards are location and EU taxonomy demands that an activity integrates physical
context specific. and non-physical measures aimed at reducing all material
This question focuses specifically on adaptation measures for risks that have been identified through a climate risk
physical risks. Climate change adaptation can be understood assessment. For existing activities, the implementation of
as anticipating the adverse effects of climate change and those physical and non-physical measures may be phased
taking appropriate action to prevent or minimize the damage and executed over a period of time of up to five years. For new
they can cause. It includes business opportunities such as activities, implementation of these measures must be met at
new technologies to use scarce water resources more the time of design and construction. (EU Technical Expert
efficiently, or the building of new flood defenses. Group, Taxonomy Report, Technical Annex).
Question Layout
Based on your climate risk assessment, has your company set up a plan to adapt to the identified physical climate risks? Please
provide supporting evidence and indicate where this is available in the public domain.
□ Yes, we have a context-specific plan to adapt to physical climate risks in existing and/or new operations. Please provide
supporting evidence and indicate if this is available in the public domain.
□ We publicly report on our context-specific plan to adapt to physical risks
□ The risk assessment and plan to adapt to physical climate risks cover the following share of our existing operations
(Percentage of total revenues):
The plan includes a target to implement relevant adaptation measures within the following timeline for existing operations:
□ Less than 5 years
□ 5 to 10 years
□ More than 10 years
□ The risk assessment and plan to adapt to physical climate risks cover the following share of our new operations (Percentage
of new operations):
□ We have no new asset planned.
□ Yes, we have an overall plan to adapt to potential physical climate risks. Please provide supporting evidence and indicate if this
is available in the public domain.
□ We publicly report on overall plan to adapt to physical risks
168 / 252
The plan includes a target to implement relevant adaptation measures within the following timeline:
□ Less than 5 years
□ 5 to 10 years
□ More than 10 years

Adaptation: Anticipating the adverse effects of climate Additional credit will be granted for public disclosure of a
change and taking appropriate action to prevent or minimize context-specific or an overall plan to adapt to physical
the damage they can cause or taking advantage of climate risks.
opportunities that may arise.
If your company has performed a climate risk assessment for
Context specific: Adaptation responds to physical climate physical risks and no material physical risks were identified,
risks that are mostly location and context specific. Due to this
nature, organizations can best assess climate related risks detailed explanation.
and mitigate them based on a context specific plan. For
example, there are in principle several engineering and non-
References
engineering options available to a coastal city to respond to
the risk resulting from increased sea level. Responses will EU, Technical Expert Group (TEG)(2020) Technical Annex on
vary according to where the city is located, its size, the technical screening criteria for economic activities that can
institutional and financial capacity of the city administration make a substantial contribution to climate change mitigation
to deal with climate risk, the technical and engineering or adaptation.
expertise available, the priority of the city, the perception of https://ec.europa.eu/info/sites/info/files/business_economy
the citizens, and other factors. The adaptation responses will _euro/banking_and_finance/documents/200309-
benefit the city that adopts them and possibly the systems sustainable-finance-teg-final-report-taxonomy-
that depend or interact with the city. annexes_en.pdf
A context-specific plan integrates physical and non-physical related information
measures aimed at reducing - to the extent possible and on a https://ec.europa.eu/finance/docs/policy/190618-climate-
best-effort basis - all material risks that have been identified related-information-reporting-guidelines_en.pdf
through a climate risk assessment

(EU Technical Expert Group, Taxonomy Report, Technical
Annex) CSRD - ESRS 2 MDR-A 68a, ESRS 2 MDR-A 68c
ESG Disclosure Standards (China) - G.2.2.4 Climate risk
New operations: refers to assets planned, under construction identification and prevention
or put in use after the current reporting cycle (i.e. after 2021 EU Taxonomy - Appendix A - Climate Change Adaptation
for the 2022 CSA).
IRIS+ - OI2092
Data Requirements SASB - HC-DY-450a.1, IF-HB-420a.2.
TCFD - Strategy b), Strategy c)
WEF Metrics - Integrating risk and opportunity into business
process
169 / 252
Emissions Reduction Targets
Assessment Focus
Question Rationale
Most industries are likely to be impacted by climate change, global challenges. Setting emission reduction targets enables
albeit to a varying degree. Consequently, they need to design companies to adopt a systematic and disciplined approach
strategies which are adapted to the size of the challenge for towards reducing their emissions. With this question, we aim
their industry. Whilst the majority of the companies focus on to find out if a company has set absolute or relative corporate
risks associated with the changing climate, some seek to targets to reduce greenhouse gas emissions.
identify and seize the business opportunities linked to these
Question Layout
Does your company have any corporate-level emissions reduction targets publicly available?
If your company also answers the question Net-Zero Commitment, please do not provide your Net-Zero target in this question, but
provide details of your related near-term emissions reduction target.
□ Yes, we have a company-wide absolute emissions target and/or an emissions intensity target publicly available that covers
Scope 1, Scope 2, and/or Scope 3 emissions. Please provide details in the table below.
Target Type and Metric
□ Absolute targets
□ Intensity targets
Intensity Metric
▪ Metric tons CO2e per square meter
▪ Metric tons CO2e per metric ton of aluminum
▪ Metric tons CO2e per metric ton of steel
▪ Metric tons CO2e per metric ton of cement
▪ Metric tons CO2e per metric ton of cardboard
▪ Grams CO2e per kilometer
▪ Metric tons CO2e per unit revenue
▪ Metric tons CO2e per unit FTE employee
▪ Metric tons CO2e per unit hour worked
▪ Metric tons CO2e per metric ton of product
▪ Metric tons of CO2e per liter of product
▪ Metric tons CO2e per unit of production
▪ Metric tons CO2e per unit of service provided
▪ Metric tons CO2e per square foot
▪ Metric tons CO2e per kilometer
▪ Metric tons CO2e per passenger kilometer
▪ Metric tons CO2e per megawatt hour (MWh)
▪ Metric tons CO2e per barrel of oil equivalent (BOE
▪ Metric tons CO2e per vehicle produced
▪ Metric tons CO2e per metric ton of ore processed
▪ Metric tons CO2e per ounce of gold
▪ Metric tons CO2e per ounce of platinum
▪ Metric tons of CO2e per metric ton of aggregate
170 / 252
▪ Metric tons of CO2e per billion (currency) funds under management
▪ Grams CO2e per revenue passenger kilometer
▪ Metric tons CO2e per USD($) value-added
Scope covered by the Target Timeframe Baseline year % reduction target Is this target validated by the
target emissions covered and from base year Science-based Targets
as a % of total base Initiative?
year emissions
□ Scope 1 + 2 Base Year Base year emissions □ Yes

combined □ No, but we have
□ Scope 1 + 2 + Target Year Percentage of total publicly committed
3 combined base year emissions to seek validation to
□ Not Known the target by the
SBTi
□ No, but we consider
the target to be
science-based
□ No, the target is not
science-based
Base Year Base year emissions □ Yes
□ Scope 1 □ No, but we have
Target Year Percentage of total publicly committed
base year emissions to seek validation to
the target by the
SBTi
the target to be
science-based
science-based
□ Scope 2 Base Year Base year emissions □ Yes
□ No, but we have
the target by the
SBTi
the target to be
science-based
science-based
□ Scope 3 Base Year Base year emissions □ Yes
□ No, but we have
the target by the
SBTi
the target to be
science-based
science-based
171 / 252
• If you report a target which only covers Scope 3,
please complete the last row only.
• If you report both combined and individual targets
Question-Specific Guidance & Definitions for all 3 scopes, please only provide individual
Absolute target: a target that describes a reduction in actual targets in the table.
emissions in a future year when compared to a base year.
Intensity target: a target that describes a future reduction in
emissions that have been normalized to a business metric
your response.
when compared to normalized emissions in a base year.
• The supporting documents must be available in the
public domain.
Intensity measure: Grams CO2e or Metric tons CO2e per
kilometre, per USD($) value-added, square meter, per unit
document(s) will not be accepted
revenue, per unit FTE employee, per unit hour worked, per
unit of production, per unit of service provided etc.
Industry-Specific Guidance:
Science-based targets: - Financial Institutions (BNK/FBN/INS)
• We expect short-term emission targets to focus on
deems necessary to meet the goals of the Paris Agreement operational emissions.
limiting global warming to well-below 2°C above pre- • Category 15 Financed emissions targets should be
industrial levels and pursuing efforts to limit warming to accounted for under the Net-Zero Targets for
Science-based targets Initiative Financed Emissions under the Decarbonization
Strategy Criteria.
Data Requirements
• We expect companies to set absolute or intensity References
emission targets. If your company has both
https://sciencebasedtargets.org/
absolute and intensity targets, please prioritize
your absolute target.
• If you provide the intensity target in this question, Standards & Frameworks
please select the intensity measure used (metric). AASB ASRS 2 - 33(a), 33(b), 33(d), 33(e), 33(g), 34(a), 36(a),
36(b)
CSRD - E1-1 14 AR 1, E1-1 16(a), E1-1 16(b), E1-4 33, E1-4
Scopes covered by the target: Scopes covered by the
34(a) AR 23-AR 24, E1-4 34(b) AR 23-AR 24, E1-4 34(e) AR 26,
ESRS 2 MDR-T 80b AR 24 - AR 26, ESRS 2 MDR-T 80d AR 24 -
emissions to be achieved in the target year compared to the
AR 26, ESRS 2 MDR-T 80e AR 24 - AR 26, ESRS 2 MDR-T 80g
base year.
AR 24 - AR 26
• If you report a target which covers Scope 1+2
EDCI - Net Zero
combined, please complete the first row and tick
GRI Disclosure - 11.2, 12.2, 305-5
IRIS+ - OD4091, OI8237
Scope 3 target in the last row.
• If you report a target which covers Scope 1+3
SASB - EM-CM-110a.2, EM-CO-110a.2, EM-EP-110a.3, EM-
combined, please complete the first row and tick
IS-110a.2, EM-MD-110a.2, EM-MM-110a.2, EM-RM-110a.2,
also add a separate
FB-AG-110a.2, FB-MP-110a.2, IF-EU-110a.3, IF-WM-110a.3,
Scope 2 target.
RR-PP-110a.2, RT-CH-110a.2, RT-CP-110a.2, TC-SC-110a.2,
• If you report a target which covers Scope 1+2+3
TR-AF-110a.2, TR-AL-110a.2, TR-CL-110a.2, TR-MT-110a.2,
combined, please complete the first row, tick
TR-RA-110a.2, TR-RO-110a.2
TCFD - Metrics & Targets c)
blank.
UNGC Questionnaire - E4.1
• If you report a target which covers Scope 1, 2 and 3
WEF Metrics - Paris-aligned GHG emissions targets
separately, please complete the Scope 1, Scope 2
and Scope 3 rows.
172 / 252
Net-Zero Commitment
Assessment Focus
Question Rationale
Companies are increasingly adopting net-zero targets in order
to align their activities with the aim of limiting global The purpose of this question is to find out if a company has
temperature rise to 1.5°C above pre-industrial levels. Due to made a net-zero commitment, how well it is aligned with the
the lack of common understanding of the definition of net- science-based targets and what activities are planned to
zero, the Science Based Targets initiative (SBTi) has reach the target. This question follows the criteria and
developed a global science-based standard for companies to definitions of the SBTi Net-Zero Standard.
set net-zero targets.
Question Layout
Has your company publicly committed to reaching net-zero GHG emissions and set targets and programs to fulfil the commitment?
Please note that this question should only be answered if a near-term absolute or relative emission reduction target is reported in the
previous question Emissions reduction targets.
□ Yes, we have publicly committed to reaching net-zero emissions across our value chain. Please provide details of a long-
term emission reduction target linked to your net-zero commitment and indicate where this is available in your public
reporting.
Target Time Frame Target scope & related emission Is the target validated by Science-Based Targets
reduction target (as % of base year initiative?
emissions)
Base Year Scope 1 & 2 □ Yes

□ No, but we have publicly committed to seek
Target Year Scope 3 validation to the target by SBTi
□ No, but we consider the target to be science-
based
□ No, the target is not science-based
Net-zero Strategy:
□ We have defined or already implemented programs or activities to achieve the emission reduction targets.
□ Scope 1 & 2
□ Scope 3
□ We intend to neutralize residual emissions and/or further mitigate emissions beyond our value chain with the following
activities:
□ Offsetting, e.g., purchasing carbon credits
□ Investing in permanent carbon removal
173 / 252
Net-zero commitment: A credible corporate net-zero
commitment includes commitments to:
• Reducing scope 1, 2, and 3 emissions to zero or to a Data Requirements
level that is consistent with reaching net-zero • This question should only be answered if a near-
emissions at the global or sector level in eligible term emission reduction target is reported in the
1.5°C-aligned pathways. previous question.
• Neutralizing any remaining emissions that could not • We will not accept targets without a Target Year
be reduced at the net-zero target year and any GHG specified.
emissions released into the atmosphere thereafter.
Target scope & related emission reduction target (as % of

Science-based targets: - base year emissions):
the latest climate science • We require data on gross emissions targets as a
deems necessary to meet the goals of the Paris Agreement percentage of the base year emissions before any
limiting global warming to well-below 2°C above pre- deductions or other adjustments that take into
industrial levels and pursuing efforts to limit warming to account offset credits, avoided emissions or
reduction attributable to sequestration of GHG.
• If you have a target that will partly met by offsetting
Science Based Targets initiative (SBTi): A global body that or CO2 removal, please report only the proportion of
defines and promotes best practices in emissions reductions the target that relates to emission reduction.
and net-zero targets in line with climate science. It provides
technical assistance, expert resources to companies who set
science-based targets, and independent assessment and
validation of those targets. The SBTi process for target setting This question requires public evidence. As public evidence,
and validation is as follows:
• Committing to a Science Based Target via a letter of public CDP reports, or information disclosed in the Science
intent
• Developing a target in line with SBTi criteria https://sciencebasedtargets.org/companies-taking-action
• Presenting target to SBTi for official validation
(within 2 years of committing)
• Communicating this validation to stakeholders
• Reporting progress against these targets annually AASB ASRS 2 - 14(a)(v), 33(a), 33(b), 33(d), 33(e), 34(a)
CSRD - E1-1 14 AR 1, E1-1 16(a), E1-1 16(b), E1-4 33, E1-4
Base Year: Companies should use the same base year for 34(e) AR 26, E1-7 60, ESRS 2 MDR-T 80b AR 24 - AR 26, ESRS
near-term targets and long-term net-zero targets. 2 MDR-T 80d AR 24 - AR 26, ESRS 2 MDR-T 80e AR 24 - AR 26,
ESRS 2 MDR-T 80g AR 24 - AR 26
Target Year: To limit global warming to 1.5°C above pre- EDCI - Net Zero
industrial levels we must reach net-zero GHG emission by ESG Disclosure Standards (China) - E.3.2.1 Greenhouse gas
2050. Hence, companies are expected to set their own net- emission reduction management
zero targets by 2050 or sooner. IRIS+ - OD4091, OI2436, OI6774, OI8237, OI9839
Residual emissions: Emissions sources that remain after a SASB - EM-CM-110a.2, EM-CO-110a.2, EM-EP-110a.3, EM-
company has included all technically or economically feasible IS-110a.2, EM-MD-110a.2, EM-MM-110a.2, EM-RM-110a.2,
emission reductions to their target. FB-AG-110a.2, FB-MP-110a.2, IF-EU-110a.3, IF-WM-110a.3,
RR-PP-110a.2, RT-CH-110a.2, RT-CP-110a.2, TC-SC-110a.2,
Beyond value chain mitigation: Mitigation action or TR-AF-110a.2, TR-AL-110a.2, TR-CL-110a.2, TR-MT-110a.2,
inv TR-RA-110a.2, TR-RO-110a.2
TCFD - Metrics & Targets c)
avoid or reduce greenhouse gas emissions, such as carbon UNGC Questionnaire - E1, E1.1
WEF Metrics - Paris-aligned GHG emissions targets, TCFD
greenhouse gases from the atmosphere and permanently implementation
store them.
174 / 252
Biodiversity
Biodiversity forms the foundation for all of life. It plays a critical role in maintaining the quality, quantity, and resilience of ecosystems
and provides services that the planet
a full price for the privilege. The externalities of these actions have brought us to a turning point either continue elevated levels of
dependency and impact on nature or follow a path to a more holistic approach. The world humans, businesses, economies face a
inesses
deeply consider their relationship with nature and work collaboratively with stakeholders to achieve mutually beneficial outcomes.
This criterion focuses on the ability of companies to recognize business operations. This criterion also seeks a high-level of
the importance of biodiversity and the impact- and industry collaboration with external stakeholders to create
dependency-related risks and opportunities. Risks must be meaningful policies, operate within supply chains and to
identified in order to alleviate pressure on ecosystems and to transform existing systems.
help them thrive, while still working within the parameters of
Biodiversity Risk Assessment
Assessment Focus
Question Rationale with nature and work collaboratively with stakeholders to

achieve mutually beneficial outcomes.
The purpose of this question is to determine to what extent
companies are taking inventory of biodiversity risks.
This question focuses on the ability of companies to
Biodiversity forms the foundation for all of life. Businesses
recognize the importance of biodiversity and related risks and
opportunities. This includes identifying risks to alleviate
full price for the privilege. The externalities of these actions
pressure on ecosystems while still working within the
have brought the planet to a turning point either continue
parameters of business operations. The risk assessment
elevated levels of dependency and impacts on nature or
should then be used to inform a company-wide risk
follow a path towards a more holistic approach. The world
management process, ideally through a location-specific
humans, businesses, economies face a risk of collapse if we
approach. This question also asks for a high level of industry
collaboration with external stakeholders to create
option asking businesses to deeply consider their relationship
meaningful processes; operate sustainably within upstream
and downstream activities; and transform existing systems.
Question Layout
Has your company assessed dependency- and impact-related biodiversity risks covering all relevant activities?
□ Yes, we have completed a biodiversity risk assessment.

Please provide supporting evidence for options selected below and indicate if the evidence is publicly available.
Process Description
Describe the processes used for identifying and assessing dependency- and impact-related biodiversity risks covering the elements
below and indicate if this information is reported in the public domain. Please provide supporting evidence:
□ We publicly report on the process steps of our biodiversity risk assessment

□ Use of location-specific approach
□ References to methodologies or frameworks used for assessment
□ Integrated into multi-disciplinary company-wide risk management processes
175 / 252
□ Dependency-related biodiversity risks considered in risk assessment
□ Impact-related biodiversity risks considered in risk assessment
Scope of biodiversity risk assessment

Please indicate the scope of your biodiversity risk assessment, and indicate if this information is reported in the public domain.
□ We publicly report on the scope of our biodiversity risk assessment

□ Own operations
□ Adjacent areas to own operations
□ Upstream activities
□ Downstream activities
Risks identified
Indicate if biodiversity risks were identified, and indicate if this information is reported in the public domain. Please provide
supporting evidence:
□ We publicly report on the biodiversity-related risks which were identified.

□ Biodiversity-related risks identified
□ No biodiversity-related risks
Question-Specific Definitions & Guidance

Location-specific approach: Refers to any dependencies or Own Operations: Includes any business activity which directly
impacts that are occurring at a particular place in a impacts natural capital through its own operations own
employees, business, subsidiaries, products and services,
business units, regions, sites, plants, and facilities. This also
Methodologies and Frameworks: A methodology refers to a includes indirect impacts that depend on critical
system of methods used for assessing biodiversity-related commodities in its supply chain. Such activities may include
risks, to assess the reliability of the assessment. A framework production, extraction, plantation, construction, power
provides a structure intended to guide the development of an generation, transmission, or development activities.
assessment. A framework is intended to assure stakeholders
that the biodiversity assessment is guided by a reliable Adjacent Areas: Value chain sites which are adjacent
foundation. Acceptable methodologies may include: (between 0 and 2km from nearest site) to landscapes,
seascapes, and watersheds critical to biodiversity.
• TNFD LEAP Nature Risk Assessment Approach
• Integrated Biodiversity Assessment Tool (IBAT) Upstream Activities: Activities that include operations that
• Species Threat Abatement and Restoration Metric relate to the initial stages of producing a good or service, e.g.
(STAR) material sourcing, material processing, and supplier
• activities. This includes brokers, consultants, contractors,
• WWF Biodiversity Risk Filter distributors, franchisees or licensees, home workers,
independent contractors, manufacturers, primary producers,
Impact: Can be a positive or negative contribution of a sub-contractors, tier-1 and 2 suppliers and wholesalers.
company toward the state of nature. Examples might include
pollution of air, water, soil; the fragmentation or disruption of Downstream Activities: Activities that include operations that
systems and natural habitats; and the alteration of relate to processing materials into a finished product and
ecosystems. delivering it to the end user (e.g. transportation, distribution
and consumption).
Dependency: Aspec
Data Requirements
a person or organization relies on to function. This might
include water flow and quality regulation; regulation of Additional credit will be granted for the public disclosure of
hazards like floods and fires; pollination; and carbon the section elements listed below:
sequestration.
• Process description
- Use of a location-specific approach
176 / 252
- References to methodologies or frameworks used for Consumer Discretionary (CNO, REX, TRT)
assessment Companies in the following industries that are only providing
• Scope of the biodiversity risk assessment
- All options need to be verifiable from public documents explanation in the comment box.
• Risk identified • CNO Casinos & Gaming industry
- All options need to be verifiable from public documents • REX Restaurants & Leisure Facilities
• TRT Hotels, Resorts & Cruise Lines
that can credibly demonstrate in a comprehensive comment Industrials (ICS)

that their company has: Companies that are not involved in waste management
• No impact on biodiversity in its own operations explanation in the comment box.

•
material supply chains
References
• No impact at the use-phase or end-of-life of
products/services use TNFD- LEAP: https://framework.tnfd.global/the-leap-nature-
• No financing activities which impact or depend on risk-assessment-process/evaluate/identification-
biodiversity environmental-assets/
Nature Positive: https://naturepositive.com/baseline-
Industry-Specific Guidance: biodiversity-assessments/
Integrated Biodiversity Assessment Tool (IBAT):
Utilities (ELC, GAS, MUW) https://www.ibat-alliance.org/
• ELC & GAS: Utilities that have no power generation
or transmission business or are only in https://encore.naturalcapital.finance/en
STAR (Species Threat Abatement and Restoration Metric):
https://www.iucn.org/resources/conservation-tool/species-
comment box. threat-abatement-and-recovery-star-metric
• MUW industry: Pure water utilities should mark WWF Risk Biodiversity Filter:
https://wwwwwfse.cdn.triggerfish.cloud/uploads/2022/05/w
comment box. wf-a-biodiversity-guide-for-business.pdf
Real Estate (REI and REM)

• Companies that have not marked 'Development of Standards & Frameworks
major renovation and new construction' as one of
the main activities of the business in question '0.1 CSRD - E4 IRO-1 17(a) AR 4-AR9, E4 IRO-1 17(b) AR 8, E4-1
13(a) AR 2-AR 3, E4-1 13(b) AR 2-AR 3, E4-1 13(e) AR 2-AR 3
• Companies that have marked 'Development of EU Taxonomy - Appendix D - Protection and Restoration of
major renovation and new construction' as one of Biodiversity and Ecosystems
the main activities of the business in question '0.1 SASB - EM-MD-160a.2, EM-SV-160a.2, IF-EN-160a.2
Denominator Area' but are only operating in urban WEF Metrics - Integrating risk and opportunity into business
env process
provide an explanation in the comment box.
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Biodiversity Commitment
Assessment Focus
Question Rationale
The purpose of this question is to evaluate the disclosure of a net loss. Furthermore, companies are expected to commit to
company's public policy or commitment to biodiversity, disclosing mitigating actions they take as well as setting a
covering aspects to systematically address its dependency long-term net positive impact commitment. All aspects
and impact-related biodiversity risks. This includes covered are expected to be applied to its entire value chain
commitments to engage with its stakeholders, conduct risk and be endorsed by either a member of the board of directors
assessments, and disclose its priority areas identified, as or executive management.
well as a commitment to setting targets to work towards no
Question Layout
Does the company have a policy, commitment, or pledge on biodiversity and is it available publicly?
□ Yes, the company has a policy, commitment, or pledge on biodiversity. Please indicate where this information is available in
Policy or Commitment aspects

The policy or commitment covers the following aspects:
□ Achievement of a net positive impact (NPI) on biodiversity

Please indicate the target year:
□ Definition of biodiversity-related targets for priority areas to work towards no net loss
□ Commitment required of value chain to avoid operational activities near sites containing globally or nationally important
biodiversity
□ Application of a mitigation hierarchy
□ Conducting a biodiversity risk assessment
□ Engagement with stakeholders on biodiversity
Scope of Commitment
Which parts of operations, corporate processes, and supply chain are covered by your biodiversity policy or commitment?
□ Own Operations
□ Suppliers
□ Partners
Policy Endorsement
□ Please select the highest endorsing decision-making body
□ Executive Management
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Net Positive Impact (NPI): Is a commitment, aligned with the • Contribution of different locations, commodities,
-2020 Global Biod suppliers to total impact of the company
• State of nature in value chain locations
chain are stabilized in the next 10 years (by 2030) and allow • Needs of value chain stakeholders, such as
for the recovery of natural ecosystems in the following 20 dependency on ecosystem services
years with net improvements by 2050 to achieve the
Risk Assessment: Businesses should carry out risk
assessments of their dependencies and impacts on
biodiversity and ecosystem services. From global risk
Mitigation Hierarchy: A framework to help companies mapping that allows companies to identify operations with a
minimize negative impacts on nature with a long-term high degree of exposure to potential biodiversity and
outlook. This prioritized approach guides companies to first, ecosystem service risks, to further site-level risk
avoid the impacts, and if not possible, to limit or reduce assessments, aimed at mitigating potential environmental
impacts on nature, and next, to hold themselves accountable and social risks.
for restoring areas and ecosystems adversely impacted by
business operations. Additionally, the option to offset or Stakeholders: Persons or groups who are directly or indirectly
compensate aims to compensate for any residual, adverse affected by a project, as well as those who may have interests
impacts after full implementation of the previous three steps in a project and/ or the ability to influence its outcome, either
of the mitigation hierarchy. Building on this, companies might positively or negatively. Examples of stakeholder engagement
take transformative actions that address the socio-economic may include any of the following:
systems in which organizations are embedded and currently • If the company collaborates with experts
accelerate biodiversity loss. (consultants and NGOs) to create their own
biodiversity strategy
Targets to work towards no net loss: Must be linked to a • Suppliers
• Local community engagement
dependency- and impact-related biodiversity risks for priority • NGOs on specific conservation or restoration
areas identified through the biodiversity risk assessments. projects
• Investee companies
Targets may be related to:
• Avoidance or reduction of sourcing from areas of Natural Capital: Is another term for the stock of renewable
critical biodiversity and non-renewable natural resources on earth (e.g., plants,
• Reduction of land use change (e.g. Deforestation) animals, air, water, soils, minerals) that combine to yield a
• Reduction of resource exploitation (e.g. water use in people. These flows can be
water-stressed areas, fisheries with stocks outside ecosystem services or abiotic services, which provide value to
biologically sustainable levels) businesses and to society.
• Restoration or regeneration in critical value chain
locations related to ecological integrity, Ecosystem services: Are defined as the direct and indirect
connectivity, soil quality, etc. contributions of ecosystems to human wellbeing and have an
• Compensation through reforestation programs / impact on survival and quality of life. There are four types of
creation of protected areas or reserves ecosystem services: provisioning (oil, timber, fiber, etc.),
regulating (pollination, flood control, climate regulation, etc.),
No Net Loss (NNL): It is defined as the point at which project- cultural (recreation, aesthetic values) and supporting services
related impacts on biodiversity are balanced by measures (photosynthesis, water/ nutrient cycles, etc.).
undertake on-site restoration, and finally to offset significant Abiotic services: Are benefits to people that do not depend on
residual impacts, if any, on an appropriate geographic scale ecological processes but arise from fundamental geological
(e.g., local, landscape-level, national, regional). processes and include the supply of minerals, metals, and oil
and gas, as well as geothermal heat, wind, tides, and the
Priority Areas: Are identified based on risk assessment data annual seasons.
to determine the relative contribution of different locations to Biodiversity:

-related risk exposure. genetic information, and the ecosystems they form. It is
Criteria for identifying priority areas may include: critical to the health and stability of natural capital as it
• High-priority sites, inputs, or product lines based on provides resilience to shocks like floods and droughts, and it
environmental and financial materiality supports fundamental processes such as the carbon and
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water cycles as well as soil formation. Therefore, biodiversity independent contractors, manufacturers, primary producers,
is both a part of natural capital and also underpins ecosystem sub-contractors, tier-1 and 2 and wholesalers
services.
Partners: Include agents, lobbyists and other intermediaries,
Critical Commodities: Raw materials which have either been joint venture and consortia partners, customers, clients
extracted (i.e. hard commodity) or grown (i.e. soft
commodity). These critical commodities either have a
Data Requirements
significant impact on biodiversity in their production process
or depend on functioning biodiversity to achieve an optimal This question requires supporting evidence from the public
output. Examples of such critical commodities (such as domain. The information provided has to be included in your
defined by the EU rules for deforestation-free products) may public reporting (e.g.: annual report, sustainability report,
include: integrated report, company publications) or corporate
• Beef website.
• Wood
• Palm oil
• Soya that can credibly demonstrate in a comprehensive comment
• Coffee that their company has:
• Cocoa • No impact on biodiversity in its own operations
•
Additionally, considering their high potential impact on material supply chains
biodiversity, we consider rubber and cotton as potential • No impact at the use-phase or end-of-life of
supply chain risks. products/services use
• No financing activities which impact or depend on
Areas: Refers to land, sea, or any other natural environment biodiversity
which is used, owned, leased, operated, or permitted by the
company Industry-Specific Guidance:
Site Proximity: Value chain sites which either contain (i.e. Utilities (ELC, GAS, MUW)
overlapping) or are adjacent (between 0 and 2km from nearest • ELC & GAS: Utilities that have no power generation
site) to landscapes, seascapes, and watersheds critical to or transmission business or are only in
biodiversity.
Sites containing globally or nationally important biodiversity: comment box.

• MUW industry: Pure water utilities should mark
include:
• Species classified as Critically Endangered, comment box.
Endangered, or Vulnerable on the IUCN Red List,
endemic species Real Estate (REI and REM)
• Internationally recognized areas: World Heritage Companies that have not marked 'Development of major
sites, Ramsar Wetlands, UNESCO MAB, Biodiversity renovation and new construction' as one of the main activities
Hotspots of the business in question '0.1 Denominator Area' should
• Nationally important biodiversity can include legally
protected areas, habitats, and species. Companies that have marked 'Development of major
renovation and new construction' as one of the main activities
Companies are expected to have a position or commitment on of the business in question '0.1 Denominator Area' but are
biodiversity and the impact of their operations, even if they do
not currently operate in sites containing globally or nationally A .
important biodiversity.
Consumer Discretionary (CNO, REX, TRT)
Own Operations: Own employees, own business, subsidiaries, Companies in the following industries that are only providing
own products and services, business units, regions, sites,
plants, facilities explanation in the comment box.
• CNO Casinos & Gaming industry
Suppliers: Include brokers, consultants, contractors, • REX Restaurants & Leisure Facilities
distributors, franchisees or licensees, home workers, • TRT Hotels, Resorts & Cruise Lines
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Industrials (ICS) gb/publications/biodiversity/mining-and-biodiversity-good-
Companies in the Commercial Services and Supplies (ICS) practice-guidance
industry that are not involved in waste management activities International Petroleum Industry Environmental Conservation
Association
the comment box. (IPIECA): https://www.ipieca.org/resources/good-
practice/biodiversity-and-ecosystem-services-
fundamentals/
References
Cross-Sector Biodiversity Initiative (CSBI)
Natural Capital guidance: http://www.csbi.org.uk/
Coalition: www.naturalcapitalcoalition.org/protocol Cement Sustainability Initiative (CSI)
Science-based Targets for Nature (SBTN) Initial Guidance for guidance: https://www.wbcsd.org/contentwbc/download/30
Business: https://sciencebasedtargetsnetwork.org/wp- 55/38872/1
content/uploads/2020/09/SBTN-initial-guidance-for- Post-2020 Global Biodiversity
business.pdf Framework: https://www.cbd.int/article/draft-1-global-
Taskforce on Nature-Related Financial Disclosure (TNFD) biodiversity-framework
NATURE IN SCOPE: https://tnfd.global/wp-
content/uploads/2021/07/TNFD-Nature-in-Scope-2.pdf
European Supervisory Authorities (ESAs) Joint Committee (JC)
draft Regulatory Technical Standards (RTS) on non-financial CSRD - E4-2 AR 12 a, E4-2 AR 16, E4-4 32(d), ESRS 2 MDR-P
disclosures: https://www.esma.europa.eu/sites/default/files 65a, ESRS 2 MDR-P 65b, ESRS 2 MDR-P 65c, ESRS 2 MDR-P
/library/jc_2021_03_joint_esas_final_report_on_rts_under_s 65d, ESRS 2 MDR-T 80c AR 24 - AR 26, ESRS 2 MDR-T 80e AR
fdr.pdf 24 - AR 26
UN Convention on Biological Diversity: https://www.cbd.int EU Taxonomy - Appendix D - Protection and Restoration of
Convention on International Trade in Endangered Species of Biodiversity and Ecosystems
Wild Fauna and Flora: https://www.cites.org/ GRI Disclosure - 101-1
UNESCO World Heritage Centre: https://whc.unesco.org/ IRIS+ - OD4091, OI1618
International Union for Conservation of SASB - EM-CM-160a.1, EM-EP-160a.1, EM-MD-160a.1
Nature: https://www.iucn.org/ UNGC Questionnaire - E1, E1.1, E3, E4.1
International Council on Mining & Metals (ICMM)
guidance: https://www.icmm.com/en-
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No Deforestation Commitment
Assessment Focus
Question Rationale
No deforestation commitments are voluntary sustainability conversion can be effective tools to achieve deforestation-
initiatives adopted by companies to signal the intention to free value chains. Engagement with external stakeholders
end all deforestation in their supply chains. Commitments to and with the entire supply chain exposed to deforestation
end all deforestation that have targets set with immediate risks, as well as monitoring and disclosure of compliance,
deadlines and clear sanction-based implementation further support effective implementation of no-deforestation
mechanisms in biomes with a high risk of forest commodity commitments.
Question Layout
Does the company have a policy or commitment on no-deforestation and is it available publicly?
□ Yes, the company has a policy or commitment on no-deforestation. Please indicate where this information is available in
Extent of Policy or Commitment

Indicate the extent of the policy or commitment to no-deforestation:
□ End all deforestation (no gross deforestation)

□ Compensate with future reforestation (no net deforestation)
Our targets are time-bound. Planned year for full implementation:
Scope of commitment
Which parts of operations, corporate processes and supply chain are covered by your no-deforestation policy or commitment?
□ Own Operations
□ Suppliers
□ Partners
Policy Endorsement
□ Please select the highest endorsing decision-making body:
□ Executive Management
Question-Specific Definitions & Guidance No net deforestation: Also referred to as zero-net

deforestation, these are promises of future reforestation to
No gross deforestation: Also referred to as zero or zero-gross
compensate current forest loss, while future implementation
deforestation, it refers to voluntary commitments to stop or
deadlines allow for preemptive clearing.
reduce all deforestation associated with commodities that
they produce, trade, and/or sell.
Scope of commitment: Effective commitments to end
deforestation must cover all products & services, and be
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applicable to all suppliers and partners. Failure to indicate
complete coverage and applicability to the value chain results
in uncertainty. comment box.
• MUW industry: Pure water utilities should mark
Own Operations: Own employees, own business, subsidiaries,
own products and services, business units, regions, sites, comment box.
plants, facilities
Real Estate (REI and REM)
Suppliers: Include brokers, consultants, contractors, Companies that have not marked 'Development of major
distributors, franchisees or licensees, home workers, renovation and new construction' as one of the main activities
independent contractors, manufacturers, primary producers, of the business in question '0.1 Denominator Area' should
sub-contractors, tier-1 and 2 and wholesalers. mark
Companies that have marked 'Development of major
Partners: Include agents, lobbyists and other intermediaries, renovation and new construction' as one of the main activities
joint venture and consortia partners, customers, clients. of the business in question '0.1 Denominator Area' but are
Commitment and oversight: A statement that the and provide an explanation in the comment box.
commitment/policy is approved, overseen, reviewed, or
adopted by the board of directors or executive management. Consumer Discretionary (CNO, REX, TRT)
A policy can also be signed by the respective director. Companies in the following industries that are only providing
explanation in the comment box.

Data Requirements
• CNO Casinos & Gaming industry
This question requires supporting evidence from the public • REX Restaurants & Leisure Facilities
domain. The information provided has to be included in your • TRT Hotels, Resorts & Cruise Lines
public reporting (e.g.: annual report, sustainability report,
integrated report, company publications, etc.) or corporate Industrials (ICS)
website. Companies in the Commercial Services and Supplies (ICS)
industry that are not involved in waste management activities
provide an explanation in
that can credibly demonstrate in a comprehensive comment the comment box.
that their company has:
• No impact on deforestation in its own operations
•
material supply chain CSRD - E4-2 24(d), E4-4 32(d), ESRS 2 MDR-P 65a, ESRS 2
• No impact on deforestation through its partner MDR-P 65b, ESRS 2 MDR-P 65c, ESRS 2 MDR-T 80c AR 24 -
relationships AR 26, ESRS 2 MDR-T 80e AR 24 - AR 26
EU Taxonomy - Multiple Objectives & Activities - DNSH (6)
Industry-Specific Guidance: IRIS+ - OD4091
UNGC Questionnaire - E1, E1.1, E17, E4.1
Utilities (ELC, GAS, MUW)
• ELC & GAS: Utilities that have no power generation
or transmission business or are only in
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05
Social Dimension
Labor Practices
Employees represent one of a company's most important companies are increasingly expected to adhere to and apply
assets. Maintaining good relations with employees is these standards equally across all operations within the
essential for the success of businesses' operations, organization. Furthermore, growing customer awareness
particularly in industries characterized by organized labor. leads to higher expectations from companies in their role as
Beyond providing a safe and healthy working environment, global corporate citizens and their ability to drive sustainable
companies should support fair treatment practices such as business practices forward.
guaranteeing diversity, ensuring equal remuneration and The key focus of the criterion is on gender diversity in
supporting freedom of association. In accordance with management, equal remuneration, and freedom of
international standards on labor and human rights, association.
Discrimination & Harassment
Assessment Focus
Question Rationale
The purpose of this question is to evaluate the quality of the companies with strong non-discriminatory practices have
-discrimination and anti-harassment policy. been proven to perform better in terms of innovation,
According to the International Labor Organization (ILO), efficiency, productivity, employee engagement and talent
discrimination based on the mentioned identity markers is a attraction and retention, thus making anti-discrimination
violation of human and labor rights. Furthermore, diverse practices a key strategic topic for companies.
Question Layout
Does the company have a policy on non-discrimination and anti-harassment at a group level and is it available publicly?
□ Yes, the company has a group-wide policy on non-discrimination and anti-harassment and it covers the following measures.
Please indicate where this information is available in public reporting or corporate website.
□ Explicit statement prohibiting harassment:
□ Sexual harassment
□ Non-sexual harassment
□ Zero tolerance policy for discrimination
□ Trainings for all employees on discrimination or harassment in the workplace
□ Defined escalation process for reporting incidents specific to discrimination and/or harassment
□ Corrective or disciplinary action taken in case of discriminatory behavior or harassment

Discrimination: Discrimination is defined as the act and the fairly on the basis of individual merit. Discrimination can also
result of treating people unequally by imposing unequal include harassment.
burdens or denying benefits, instead of treating each person
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Harassment: Harassment is defined as a course of comments This question requires publicly available information.
or actions that are unwelcome, or should reasonably be
known to be unwelcome, to the person towards whom they We expect companies to have a statement explicitly
are addressed. Non-sexual harassment includes but is not prohibiting both sexual and non-sexual harassment.
exclusive to mobbing and bullying, while sexual harassment
includes a sexual component. We expect the company's policies and measures to be
explicitly relevant to discrimination and harassment. A simple
Zero tolerance: Zero-tolerance policies against harass- mention of discrimination in the Codes of Conduct is not
ment and discrimination dictate that any allegations are considered sufficient. If discrimination and harassment are
taken seriously and handled confidentially and included in trainings, escalation processes and disciplinary
sympatheticcally. If allegations are confirmed, remedial actions together with other breaches of the Codes of Conduct,
action, disciplinary action, dismissal, or legal action will be it should be mentioned that each aspect also covers
taken. discrimination and harassment specifically.
Defined escalation process: System consisting of specific Please note: If you have less than 100 employees or no
employees in your organization, then please mark the
procedures, roles and rules for receiving complaints and question as 'Not applicable'.
providing remedy. Grievance mechanisms are also accepted
here. It should be specifically specified in the company's
References
public domain that discrimination and harassment incidents
are to be reported through the defined escalation process. • ILO: Convention no. 111
• ILO: Business, Discrimination and Equality
Corrective action: Corrective action is a process of
communicating with the employee and taking active Standards & frameworks
measures to improve unacceptable behavior.
CSRD - S1-1 24a, S1-1 24d, S1-3 32b
Disciplinary action: A disciplinary action is a reprimand or ESG Disclosure Standards (China) - S.1.1.2 Employee
corrective action in response to employee misconduct, rule diversity and equality
violation, or poor performance. Depending on the severity of IRIS+ - OI5102, OI9088, OI9331
the case, a disciplinary action can take different forms, SASB - SV-HL-310a.4
including a verbal warning, a written warning, a poor UNGC Questionnaire - G2, G8, L1.1, L3, L4
performance review or evaluation, a reduction in rank or pay UNGP - A1, A2.3, C1, C6, C6.1, C6.2, C6.3
and termination.
Data Requirements
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Workforce Breakdown: Gender
Assessment Focus
Question Rationale
We assess various Labor KPIs of an organization to determine retention practices will therefore benefit from positive
not only the quality, but also the transparency of its reporting recognition and lower compliance costs in the future.
performance as it increases the likelihood of bringing people This question specifically assesses workforce gender
with different types of knowledge, views and perspectives diversity by asking about the proportion of women at different
together. This diversity results in better innovative and levels of responsibility. We expect companies to also commit
problem-solving skills, improves talent attraction and to gender balance across the talent pipeline by setting
retention, increases employee engagement and results in targets for the levels of representation where they face the
higher efficiency. Several initiatives have already been taken greatest challenges. This question looks at the companies'
by shareholders and governments to increase the share of ability to disclose this data, as well as its performance
women in the workforce and in leadership positions. compared to its industry peers and its ability to retain women
Companies who are early adopters of inclusive hiring and talent.
Question Layout
Does your company monitor the following indicators regarding workforce gender diversity? If so, please complete the table. Please
provide the coverage reported on as a percentage of FTEs and attach supporting public evidence where indicated if available.
Please also indicate whether you have set a public target for women representation. We expect companies to have set at least one
public target for one representation level in order to meet our requirements for the targets. We do not expect companies to have
targets for each level of representation.
□ Yes, we monitor the following indicators:

Please select the coverage of the data reported on as a % of FTEs:
Diversity Indicator Percentage (0 - 100 %) Public Target

Share of women in total workforce (as % Target year:
of total workforce) □ Public reporting available: □ Public reporting:
Share of women in all management Target year:
positions, including junior, middle and □ Public reporting:
top management (as % of total □ Public reporting available:
management positions)
Share of women in junior management Target year:
positions, i.e. first level of management □ Public reporting:
(as % of total junior management □ Public reporting available:
positions)
Share of women in top management Target year:
positions, i.e. maximum two levels away □ Public reporting:
from the CEO or comparable positions (as □ Public reporting available:
% of total top management positions)
Share of women in management Target year:
positions in revenue-generating □ Public reporting:
functions (e.g. sales) as % of all such □ Public reporting available:
managers (i.e. excluding support
functions such as HR, IT, Legal, etc.)
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Share of women in STEM-related Target year:
positions (as % of total STEM positions) □ Public reporting available: □ Public reporting:
Question-Specific Definitions & Guidance functions such as HR, IT, Legal. May also be referred to as
roles that have P&L responsibility.
The definitions provided below are guidelines that should be
followed as closely as possible. If a different definition is
STEM: Science, Technology, Engineering, and Mathematics.
used, this should be explained accordingly, and a consistent
STEM workers use their knowledge of science, technology,
definition should be used in any other questions that may
engineering, or mathematics in their daily responsibilities. To
require information about organizational structures.
be classified as a STEM employee, the employee should have
a STEM-related qualification and make use of these skills in
Gender identity:
their operational position. Positions include, but are not
individual experience of gender, which may or may not
limited to, the following: Computer programmer, web
correspond to the sex assigned at birth, including the
developer, statistician, logistician, engineer, physicist,
personal sense of the body (which may involve, if freely
scientist.
chosen, modification of bodily appearance or function by
medical, surgical or other means) and other expressions of
Coverage: The coverage corresponds to the scope of the data
gender, including dress, speech and mannerisms (European
reported on. For example, if a company only reports on its
Institute for Gender Equality). In this question, we refer to
employees in one country, and these employees represent X%
employees who self-identify as women, i.e., who consider
of the total workforce, then the company should select the
their gender identity to be woman.
bracket which includes this X%. Please us a consistent
coverage for all the indicators.
Management positions: This refers to all levels of
management, including junior, middle, and senior level
management. Data Requirements
Junior management positions: refer to first-line managers,
question. Additional credit will be granted for relevant
junior managers, and the lowest level of management within a
publicly available evidence covering each of the following
aspects of this question:
typically responsible for directing and executing the day-to-
• Women in the total workforce
day operational objectives of organizations, conveying the
• Women in all management positions
directions of higher-level officials and managers to
• Women in junior management positions
subordinate personnel.
• Women in top management positions
• Women in revenue-generating positions
Middle management positions: refer to managers who head
• Women in STEM-related positions
specific departments (such as accounting, marketing,
production) or business units, or who serve as project
We expect companies to have set at least one public target
managers in flat organizations. Middle managers are
for one representation level in order to meet our requirements
responsible for implementing the top management's policies
for the targets. We do not expect companies to have public
and plans and typically have two management levels below
targets for each level of representation, but only for one level.
them.
This target needs to be publicly available or will not be
considered as relevant in the scoring of this question.
Top management positions: refer to management positions
with a reporting line at most two levels away from the CEO.
Please note: If you have less than 100 employees or no
They include individuals who plan, direct, and formulate
policies, set strategy, and provide the overall direction of
question as 'Not applicable'.
enterprises/organizations for the development and delivery of
products or services, within the parameters approved by
References
boards of directors or other governing bodies.
• The gender equality questions were developed in
Revenue-generating functions: refer to line management collaboration with EDGE, leveraging its robust research
roles in departments such as sales, or that contribute directly on gender equality. EDGE is the leading global
to the output of products or services. It excludes support assessment methodology and business certification
standard for gender equality. It measures where
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organizations stand in terms of gender balance across Standards & frameworks
their pipeline, pay equity, effectiveness of policies and
CSRD - ESRS 2 MDR-T 80b AR 24 - AR 26, ESRS 2 MDR-T 80e
practices to ensure equitable career flows as well as
AR 24 - AR 26, S1-6 50a AR 57, S1-9 66a
inclusiveness of their culture. Launched at the World
ESG Disclosure Standards (China) - S.1.1.2 Employee
Economic Forum in 2011, EDGE has been designed to
diversity and equality
help companies not only create an optimal workplace
GISD - Diversity and inclusion (%), Proportion of women in
for women and men, but also benefit from it. EDGE
managerial positions
stands for Economic Dividends for Gender Equality and
is distinguished by its rigor and focus on business
IRIS+ - OD4091, OI1571, OI2444, OI6213
SASB - CG-EC-330a.3, CG-MR-330a.1, FN-AC-330a.1, FN-IB-
consists of 200 large organizations in 44 countries
330a.1, SV-AD-330a.1, SV-ME-260a.1, SV-PS-330a.1, TC-HW-
across five continents, representing 29 different
330a.1, TC-IM-330a.3, TC-SI-330a.3
industries and employing globally more than 2.4 million
UNGC Questionnaire - L7
employees.
WEF Metrics - Diversity and inclusion (%)
• ILO convention No. 111
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Workforce Breakdown: Race/ Ethnicity & Nationality
Assessment Focus
Question Rationale
Provisions on equality and non-discrimination are enshrined and ethnic diversity is difficult but not impossible. This
in international human rights law and in the constitutions and question seeks to encourage companies to measure the racial
legislations of most countries. Nonetheless, many people and ethnic composition of their workforce in order to
continue to face prejudice, harassment, and discrimination understand whether it fairly represents the broader
because of their ethnic or racial origins. According to the demographic composition of their geographical locations.
OECD, the collection of accurate and comprehensive data on Collecting and disclosing this data is key to identifying any
diversity is therefore central to providing information on the practices of discrimination or unequal opportunities and
racial and ethnic breakdown to implementing, monitoring, provides an important indicator to shareholders that diversity
and evaluating practices and policies that aim to address and inclusion are considered as high on the corporate agenda.
disadvantages and promote equal opportunities in all sectors Indeed, the attention of shareholders and regulatory agencies
of society. is now expanding to include diversity factors such as ethnic
and racial diversity. Companies that are early adopters of
To achieve the optimum mix of skills, backgrounds and inclusive hiring and retention practices and are transparent
experience, workforce diversity needs to go beyond about these indicators will therefore benefit from positive
discussing the percentage of women to also include other recognition and lower compliance costs in the future.
diversity indicators. Collecting and analyzing data on racial
Question Layout
Does your company provide a breakdown of its workforce according to racial and ethnic self-identifications, or nationality? Please
refer to the information button for further guidance on which option to select.
Please provide the coverage reported on as a percentage of FTEs and attach supporting public evidence where indicated, if available.
□ At least 20% of our workforce is based in the US and we monitor the breakdown of our workforce according to ethnic and
racial indicators.
Breakdown Share in total workforce Share in all management positions,

(as % of total workforce) including junior, middle and senior
management
(as % of total management workforce)
Asian
Black or African American
Hispanic or Latino
White
Indigenous or Native
Other, please specify
This information is publicly available. Please provide supporting evidence:
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□ Less than 20% of our workforce is based in the US and we monitor the breakdown of our workforce according to under-
represented and structurally disadvantaged ethnic and racial minorities. If you are not able or allowed to provide such a
breakdown, please report on the breakdown of your workforce based on nationality. Please fill in the table below with the
relevant categories used.
□ We report on the breakdown of our workforce based on ethnic and racial minorities. Please specify the ethnic and
racial categories in the table below.
□ We are not able or allowed to report on ethnic and racial minorities, and therefore provide a breakdown based on
nationality. Please specify the nationalities which make up the highest percentage of your workforce in the table
below.
□ This information is publicly available. Please provide supporting evidence:
Breakdown based on, please specify: Share in total workforce Share in all management positions,
(as % of total workforce) including junior, middle and senior
management
(as % of total management workforce)
Category Name:
Category Name:
Category Name:
Category Name:
Category Name:
Category Name:

Self-identification: This refers to the assigning of a particular Ethnicity: Describes a shared culture: the practices, values,
characteristic or categorization to oneself. In this question, and beliefs that characterize those belonging to a community.
we ask for the proportion of employees who self-identify as This multidimensional concept acts as an umbrella term
such, meaning that they have expressed their identification encompassing language, religion traditions and others
with this characteristic rather than having been assigned it by (United Nations, 2017). A number of related concepts,
others based on physical or other attributes. including ancestry, citizenship, and nationality, may overlap
with ethnicity. However, ethnicity is not the same as
Structurally disadvantaged racial and ethnic nationality or citizenship, nor it is a measure of biology or
minorities: Minorities that experience a higher risk of poverty, genes. (OECD, 2018)
social exclusion, discrimination, and violence than the
general population, based on race or ethnicity. Structural Indigenous identity: While no universal definition exists in
disadvantage refers to disadvantage experienced as a result
of the way society functions, for example how institutions are whose social, cultural and economic conditions distinguish
organized, who has power, how resources are distributed, them from other sections of the national community, and
how people relate to each other, etc. This question focuses on whose status is regulated (wholly or partially) by their own
such minorities. customs or traditions or by special laws or regulations; and to
peoples in independent countries who are regarded as
Race: In the absence of any internationally agreed definition, indigenous on account of their descent from the populations
race is most often statistically characterized in terms of which inhabited the country (or a geographical region thereof)
phenotype and appearance (e.g., skin colors), or with regard at the time of conquest, colonization or establishment of
to ancestry. This should not be understood as an attempt to present state, and who, irrespective of their legal status,
trace the definition of race to biological, anthropological, or retain some or all of their own social, economic, cultural and
genetic factors but rather to (somewhat artificially)
distinguish it from the concept of ethnicity. (OECD, 2018)
190 / 252
Migrant background/origin: A person who has migrated into Disclosure requirements for partially public question:
their present country of residence; and/or previously had a Additional credit will be granted for relevant publicly available
different nationality from their present country of residence; evidence covering at least one level of responsibility for at
and/or at least one of their parents previously entered their least three minority groups.
present country of residence as a migrant (European
Commission). In some countries, migrant origins are used as a If your company has more than 20% of its workforce in the
proxy for ethnicity. US, then we require you to select the first option and report
according to the categories defined in the table. We expect
Foreign origin: A person who was born outside of the country public disclosure on at least three categories. If more than
of residence; and/or holds another nationality from their 20% of your workforce is in the US, but you also have
present country of residence; and/or at least one of their employees in other parts of the world, please select the
parents were born outside of the country of residence or hold coverage bracket which covers your employees in the US. You
nationality from another country. In some countries, foreign will not be penalized for not reporting on the full coverage of
origins are used as a proxy for ethnicity. your FTEs as we recognize that the data is complex to
consolidate at the global level.
Nationality: Generally defined as being a member of a given

state. Nationality can be acquired by birth or adoption, If your company has less than 20% of its workforce in the US,
marriage, descent, or naturalization. Based on international please select the second option and fill in the table according
conventions, every sovereign state is entitled to determine to the relevant categories for the highest share of your
who can be a national of their country. workforce. We expect public disclosure on at least three
categories. Please select the coverage bracket which covers
Coverage: The coverage corresponds to the scope of the data the scope of employees you are reporting on. You will not be
reported. For example, if a company only reports on its penalized for not reporting on the full coverage of your FTEs
employees in one country, and these employees represent X% as we recognize that the data is complex to consolidate at the
of the total workforce, then the company should select the global level.
bracket which includes this X%. If the company gave the

opportunity to self-report to its employees, but a proportion If your company has less than 20% of its workforce in the US
of these employees have actively decided to refrain from and you are unable or not allowed to report on ethnic and
providing this personal data, the proportion of these racial indicators, please select the second option and report
employees can still be included as part of the coverage. on the nationalities which make up the highest share of your
workforce. Please note that this is not the preferred option as
nationality is an imperfect proxy for the diversity indicator
Data Requirements assessed in this question. We do not accept disclosure on the
geographical spread of the workforce, here we refer to the
In Europe, according to the Article 9 of the GDPR, it is
nationalities of the employees rather than their geographical
prohibited to process personal data revealing racial or ethnic
location. We expect disclosure on at least three different
origin, except if the data subject has given explicit consent to
nationalities.
the processing of those personal data, provided this is not
prohibited by national law. Other exemptions exist, such as
Please note: If you have less than 100 employees or no
reasons of substantial public interest which might include
statistical research purposes for equality of opportunity and
treatment. However, if as a result, your company does not
collect racial or ethnic data, please report on the nationalities
which make up the highest percentage of your employees, References
ILO convention No. 111
Not Applicable will not be accepted, as we
GDPR Article 9
expect companies to report on the breakdown of
nationalities.
We expect companies to report on at least three distinct GISD - Diversity and inclusion (%)
categories (racial or ethnic categories, or nationalities) in GRI Disclosure - 405-1
order to score full points for this question. The coverage IRIS+ - OI3140, OI3236, OI8147
provides an indication of the scope of the data reported on SASB - CG-EC-330a.3, CG-MR-330a.1, FN-AC-330a.1, FN-IB-
but is not considered in the scoring of this question as we 330a.1, SV-AD-330a.1, SV-ME-260a.1, SV-PS-330a.1, TC-HW-
recognize that the data is complex to consolidate at the 330a.1, TC-IM-330a.1, TC-IM-330a.3, TC-SI-330a.3
global level. WEF Metrics - Diversity and inclusion (%)
191 / 252
Gender Pay Indicators
Assessment Focus
Question Rationale
This question assesses a importance. Furthermore, unequal remuneration and gender
evaluating the results of its gender pay assessments. An
increasing number of countries are adopting regulations retain women talent, lowers employee engagement and can
which require companies to conduct such pay assessments lead to reputationally damaging controversies.
and to disclose the results, making this topic of high strategic
Question Layout
Does your company monitor and disclose the results of your gender pay gap or equal pay assessment? If your company conducts both,
please select the option with the highest coverage.
□ We monitor and disclose the results of our equal pay analysis.
Currency:
Please provide the coverage reported on (as a % of FTEs):
Employee Level Average Women Salary Average Men Salary
Executive level (base salary only)
Executive level (base salary + other cash

incentives)
Management level (base salary only)
Management level (base salary + other cash

incentives)
Non-management level (base salary only)
□ If the equal pay information (or the ratio) is publicly reported, please provide the relevant URL.
□ Our equal pay assessment is third-party verified. Please provide supporting evidence:
o We monitor and disclose the results of our gender pay gap analysis.
□ If the gender pay gap information is publicly reported, please provide the relevant URL.
192 / 252
Please provide the coverage reported on (as a % of FTEs):
Indicator Difference between men and women employees (%)
Mean gender pay gap
Median gender pay gap
Mean bonus gap
Median bonus gap
□ Our gender pay gap assessment is third-party verified. Please provide supporting evidence:
□ We conduct gender pay assessments but do not disclose the results. Please provide supporting qualitative evidence:
Question-Specific Guidance & Definitions Mean gender pay gap: The difference between the mean
hourly rate of pay of male full-pay relevant employees and
Executive level: Employees who have an executive function
that of female full-pay relevant employees.
and play a strategic role within an organization. They hold
senior positions and impact company-wide decisions.
Median gender pay gap: The difference between the median
Executives usually report directly to the CEO and the CEO is
hourly rate of pay of male full-pay relevant employees and
included in the definition of executive level.
that of female full-pay relevant employees.
Management level: All management-level positions from

Mean bonus gap: The difference between the mean bonus
first-line/junior managers up to top/senior managers with a
paid to male relevant employees and that paid to female
reporting line 2 levels or less from the CEO, but excluding
relevant employees.
executive-level positions. Managerial functions are those that
involve planning, policy making, strategizing, leading and
Median bonus gap: The difference between the median
controlling.
bonus paid to male relevant employees and that paid to
female relevant employees.
Non-management level: Employees in charge of
executionary functions, such as production and
Coverage: Please select the coverage range on which you are
administrative positions. These employees have limited or no
reporting. For example, if you are reporting on your employees
managerial role.
in country ABC, and these employees make up 80% of your
Other cash incentives: These are monetary incentives paid
for job performance or longevity. These incentives have an Data Requirements

explicit monetary value and can include rewards such as Disclosure requirements for partially public question:
bonuses and stock options. Additional credit will be granted for relevant publicly available
evidence disclosing the metrics requested either for equal
Equal pay: Equal pay compares the salary of men and women remuneration or for the gender pay gap.
who have the same or equivalent positions to assess whether
they are paid the same for equal work. If your company conducts both equal pay and gender pay gap
assessments, please select the option for which you have
Gender pay gap: The gender pay gap is the difference in data for the highest proportion of your employees.
average gross hourly earnings between women and men it
therefore assesses the difference in pay at the aggregated Please note: If you have less than 100 employees or no
level. Calculated this way, the gender pay gap does not take in employees in your organization, then please mark the
to account all the different factors that may play a role, for question as 'Not applicable'.
example, education, hours worked, type of job, career breaks
or part-time work. However, it reflects the work that women References
do and their position in the company hierarchy, therefore also
International standards: ILO convention No. 111
providing an indicator of equality of opportunities to develop
-paid positions.
193 / 252
The gender equality questions were developed in The study
collaboration with EDGE, leveraging its robust research on (January 2019) examined the effect of pay
gender equality. EDGE is the leading global assessment transparency on the gender pay gap and firm outcomes by
methodology and business certification standard for gender examining a 2006 policy change in Denmark that required
equality. It measures where organizations stand in terms of firms to provide gender dis-aggregated wage statistics. Using
gender balance across their pipeline, pay equity, detailed data and a differences-in-differences statistical
effectiveness of policies and practices to ensure equitable approach, Bennedsen et al found that the law indeed reduced
career flows and inclusiveness of their culture. Launched at the gender pay gap.
the World Economic Forum in 2011, EDGE has been designed
to help companies not only create an optimal workplace for Standards & frameworks
women and men, but also benefit from it. EDGE stands for
CSRD - S1-16 97a AR 98-AR 100, S1-16 98
Economic Dividends for Gender Equality and is distinguished
GISD - Gender pay equality (%)
by its rigor and focus on business impact. EDGE
IRIS+ - OI1855, OI3819
organizations in 44 countries across five continents,
UNGC Questionnaire - L8
representing 29 different industries and employing globally
WEF Metrics - Pay equality (%), Pay gap (%)
more than 2.4 million employees.
194 / 252
Freedom of Association
Assessment Focus
Question Rationale
We assess various Labor KPIs at an organization to determine company allows employees to join an independent trade
the quality and transparency of its reporting. In line with ILO union.
Convention No. 87 and No. 98, this question assesses if your
Question Layout
What percent of your total number of employees are represented by an independent trade union or covered by collective bargaining
agreements? Please indicate where this is available in your public reporting.
Please note: employees who are eligible but are not actually covered by collective bargaining agreements should be excluded from
the count.
% of employees represented by an independent trade Link to public reporting

union or covered by collective bargaining agreements:
Question Specific Guidance & Definitions Please note: If you have less than 100 employees or no
Collective bargaining agreements: Written legal contracts
between an employer and a union representing the
employees. These agreements can be at the sector, national,
regional, organizational, or workplace level.
An independent trade union: A trade union which is not under CSRD - S1-8 60a AR 66
the control of an employer or group of employers or of one or ESG Disclosure Standards (China) - S.1.2.1 Democratic
more employers' associations, and is free from interference management of employees
by an employer or any such group or association. GISD - Percentage of employees covered by collective
agreement
Data Requirements IRIS+ - OI3703
Percentage of employees covered by collective bargaining SASB - EM-CO-310a.1, EM-MM-310a.1, FB-FR-310a.2, IF-
agreements: Employees who are eligible but are not actually WM-310a.1, TR-AL-310a.1, TR-AU-310a.1
covered by collective bargaining agreements should be UNGC Questionnaire - L6
excluded from the count. WEF Metrics - Freedom of association and collective
bargaining at risk (%)
This question requires public evidence.
195 / 252
Human Rights
The questions in this criterion aim to assess whether or not companies are meeting the implementation requirements of the UN
guiding principles for business and human rights.
Human Rights Commitment
Assessment Focus
Question Rationale
The purpose of this question is to identify companies that them and whether they highlight particular human rights for
have an active commitment to respect human rights in their attention, whether the commitment is limited to a particular
business relationships in line with the UN Guiding Principles set of rights, encompasses all internationally recognized
or another internationally accepted standard. The policy human rights, or encompasses all internationally recognized
needs to be company-specific with a company-wide human rights but highlights some as needing particular
commitment and not just for a single site, business unit, or attention according to the context in which the company
project. operates.
Following the most recent international developments in the

field of corporate non-financial disclosures, we want to know approach to human rights, building increased trust with
not only the coverage of businesses human rights policies but different stakeholders and demonstrating international good
what are the specific human rights issues considered within business practice.
Question Layout
Does the company have a policy on its commitment to respect human rights at a company-wide level and is it available publicly?
□ Yes, the company has policy on its commitment to respect human rights at a company-wide level. Please indicate where
this information in public reporting or corporate website.
❑ A statement of commitment to respect human rights in accordance with internationally accepted standards
❑ A statement of commitment to prevent/respect at least:
□ Human trafficking
□ Forced labor
□ Child labor
□ Freedom of association
□ The right to collective bargaining
□ Equal remuneration
□ Discrimination
□ Other rights:
The policy also covers the following:

□ Requirements for our own operations (employees, direct activities, products, or services)
□ Requirements for our suppliers
□ Requirements for our partners
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Respecting human rights: Right to non-discrimination: The principle of non-
• Avoid causing or contributing to adverse human rights
impacts through their own activities, and address such exercised without discrimination of any kind based on race,
impacts when they occur color, sex, language, religion, political or other opinion,
• Seek to prevent or mitigate adverse human rights national or social origin, property, birth or other status such
impacts that are linked to their operations, products, or as disability, age, marital and family status, sexual
services by their business relationships, even if they orientation and gender identity, health status, place of
have not contributed to those impacts. residence, economic and social situation.
Suppliers: Include brokers, consultants, contractors,

distributors, franchisees or licensees, home workers,
Data Requirements
independent contractors, manufacturers, primary producers,
sub-contractors, and wholesalers.
domain. The information provided must be included in your
Partners: Include agents, lobbyists and other intermediaries,
joint venture and consortia partners, governments,
website.
customers, clients, local communities.
Only referring to or being a signatory to external entities such

Human trafficking: The recruitment, transport, transfer,
as the UN Global Compact (UNGC) or International Labour
harboring, or receipt of a person by such means as threat or
Organization (ILO) is not sufficient for the statement of
use of force or other forms of coercion, abduction, fraud, or
commitment. A letter from your company to the UNGC is also
deception for the purpose of exploitation.
not sufficient. We require a company-specific statement of
commitment.
Forced labor: Forced labor can be understood as work that is
performed involuntarily and under the menace of any penalty.
Also, Modern Slavery Statements will not be accepted as
It refers to situations in which persons are coerced to work
human rights commitments.
through violence or intimidation, or by more subtle means
such as manipulated debt, retention of identity papers or
threats of denunciation to immigration authorities. References
Office of the High Commissioner for Human
Child labor: Work that deprives children of their childhood,
Rights: http://www.ohchr.org/Documents/Publications/Guidi
their potential and their dignity, and that is harmful to
ngPrinciplesBusinessHR_EN.pdf
physical and mental development. It refers to work that:
Business & Human Rights Resource Center:
• is mentally, physically, socially, or morally
https://www.business-humanrights.org/en/big-issues/un-
dangerous and harmful to children; and/or
guiding-principles-on-business-human-rights/
• interferes with their schooling by depriving them of
UN Global Compact guide to developing a
the opportunity to attend school; obliging them to
policy: https://www.unglobalcompact.org/docs/issues_doc/
leave school prematurely; or requiring them to
human_rights/Resources/HR_Policy_Guide_2nd_Edition.pdf
attempt to combine school attendance with
excessively long and heavy work.
Freedom of association: The right of workers and employers
CSRD - ESRS 2 MDR-P 65a, ESRS 2 MDR-P 65b, S1-1 20a, S1-
to form and join organizations of their own choosing
1 21 AR 12, S1-1 22, S1-1 24a, S1-2 AR 25 e, S1-4 AR 35, S2-1
17a, S2-1 18, S2-1 19 AR 14, S2-2 22d AR 19-AR 20, S2-4 AR
Right to collective bargaining: The right of workers to bargain
30, S3-1 17 AR 10, S3-4 AR 27, S4-1 16(a), S4-1 17 AR 11
freely with employers is an essential element in freedom of
GISD - Alignment with the UN Guiding Principle for Business
association. Collective bargaining is a voluntary process
and Human Rights
through which employers and workers discuss and negotiate
IAST APAC - Core Modern Slavery Metrics
their relations, particularly terms and conditions of work.
IRIS+ - OI4432, OI5102, OI9650
UNGC Questionnaire - G2, G3, HR2, HR2.1, L1, L1.1
Equal remuneration: This means principle of equal
UNGP - A1, A1.3, C1, C1.1
remuneration for men and women workers for work of equal
value.
197 / 252
Human Rights Due Diligence Process
Assessment Focus
Question Rationale
The purpose of this question is to assess whether your
company has a due diligence process to proactively and A passive approach such as whistle blowing, or confidential
systematically identify potential human rights impacts and reporting system is not sufficient for this question.
where they could occur. Here we ask about the scope of your
due diligence risk identification process, whether it covers There is an increasing number of studies addressing the link
only your own operations or also your value chain and other between good corporate performance, human rights, and
activities, and whether you perform a human rights due financial returns. For example, some studies indicate that
diligence process before entering into new business businesses that properly address human rights issues are
relationships (mergers, acquisitions, joint ventures, etc.). We likely to have a more productive and more profitable
also focus on the type of issues you have specifically workforce and avoid costly risks. (Baglayan, Basak & Landau,
addressed when carrying out the due diligence process and Ingrid & McVey, Marisa & Wodajo, Kebene. Good Business:
what type of vulnerable groups you have clearly considered The Economic Case for Protecting Human Rights, 2018)
throughout the process.
Question Layout
Does the company have a company-wide human rights due diligence process to proactively identify and assess potential impacts and
risks relating to respecting human rights and is it available publicly?
□ Yes, the company has a company -wide human rights due diligence process. Please indicate where this information is
□ Risk identification in our own operations

□ Risk identification in our value chain or other activities related to our business
□ Risk identification in new business relations (mergers, acquisitions, joint ventures...)
□ We do a systematic periodic review of the risk mapping of potential issues
Please indicate the issues and vulnerable groups covered in your due diligence risk identification process. Please attach public
supporting evidence for all of the aspects covered.
Actual or potential human rights issues covered/identified:

Check all that apply and provide relevant evidence for each issue covered. We expect at least four issues to be covered.
□ Human trafficking
□ Forced labor
□ Child labor
□ Freedom of association
□ The right to collective bargaining
□ Equal remuneration
□ Discrimination
□ Others, please specify:
Groups at risk of human rights issues covered/identified:

Check all that apply and provide evidence for each group covered. We expect at least four groups to be covered.
198 / 252
□ Own employees
□ Women
□ Children
□ Indigenous people
□ Migrant workers
□ Third-party employees
□ Local communities
□ Others, please specify:
□ No, the company has yet to conduct any assessments but is developing a human rights due diligence process. Please
provide information indicating the status and expected completion date.
For the actual or potential human rights issues identified, we
Question-Specific Guidance & Definitions expect evidence that some of the listed issues were identified
or covered as part of the risk identification process.
Adverse human rights impact:
For the groups at risk, we expect public evidence on the
of an individual to enjoy his or her human rights. vulnerable groups you have taken into account in the risk
identification process (we expect public proof of having
Human rights risks: The risks that a company's considered the specific risks faced by those groups or of
operations/activities/products pose to people's fundamental having considered them as relevant stakeholders through the
human rights. process). We do not expect all issues and all groups to be
covered.
Human rights due diligence: Understood as the process
through which enterprises can identify, prevent, mitigate, and The outcomes of conducting the risk identification process
account for how they address their actual and potential
adverse impacts as an integral part of business decision- ive approach such as a
making and risk management systems. Due diligence can be whistleblowing or confidential reporting system is not
included within broader enterprise risk management sufficient for this question.
systems, provided that it goes beyond simply identifying and
managing material risks to the enterprise itself, to include the
References
risks of adverse impacts related to human rights.
OECD Guidelines for Multinational Enterprises, Chapter
Data Requirements IV. https://www.oecd.org/daf/inv/mne/48004323.pdf

OECD Due Diligence Guidance for Responsible Business
Supporting documentation should be recent, provide a clear Conduct. https://www.oecd.org/investment/due-diligence-
description of the due diligence process, indicate the guidance-for-responsible-business-conduct.htm
coverage of business activities and demonstrate that it is an
ongoing activity.
The information should be available in the public domain. The CSRD - ESRS 2 GOV-4 30 AR 8 - AR 10, ESRS 2 GOV-4 32 AR 8
information provided must be included in your public - AR 10, S1-2 AR 25 e, S1-4 AR 35, S2-4 AR 30, S3-1 16a, S3-4
reporting (e.g., annual report, sustainability report, integrated 36, S3-4 AR 27
report, company publications, etc.) or corporate website. GRI Disclosure - 2-23, 407-1, 408-1, 409-1, 414-2
SASB - EM-MM-210a.3, RR-FM-210a.2
UNGC Questionnaire - G6, G7, HR1, HR3, L2
UNGP - A1, A1.2, A2, B1, B2, C1
199 / 252
Human Rights Assessment
Assessment Focus
Question Rationale
The purpose of this question is to assess the extent your
company is proactively identifying where risks are and those activities.
managing them. The process should consider the country (Source: https://www.unglobalcompact.org/docs/news_even
contexts in which the organisation operates, the potential ts/8.1/human_rights_translated.pdf)
and actual human rights impacts resulting from the
Question Layout
Has your company conducted an assessment of potential human rights issues across your business activities in the past three years?
□ Yes, We have proactively conducted an assessment of potential human rights issues in the last 3 years.
Please complete the table below related to the portion of activities assessed, the portion of activities where risks have been
identified, and the portion of activities with mitigation actions taken. If any of the business categories are not material to your
company, select "Not relevant" and provide an explanation.
If an entity has been assessed multiple times in the last three years, it should only be counted once.
A. % of total B. % of total assessed (column C. % of risk (column B) with

assessed in last A) where risks have been mitigation actions taken
Category
three years identified
□ Own Operations (including Joint

Ventures where the company
has management control)
Please select the basis for reporting
(denominator): as a % of:
□ Not relevant
□ Contractors and Tier I Suppliers
(as a % of contractors or Tier I
Suppliers)
□ Not relevant
□ Joint Ventures (including stakes
above 10%) (as a % of joint
ventures)
□ Not applicable. We do not have
any joint ventures at stakes
above 10%.

Own Operations: Includes direct activities, own employees, manufacturers, primary producers, sub-contractors, and
own sites, own products/services wholesalers.
Contractors and Tier 1 Suppliers: Include brokers, Joint ventures (including stakes above 10%): all joint
consultants, contractors, distributors, franchisees or ventures not included in Own Operations as defined above.
licensees, home workers, independent contractors,
200 / 252
Percentage of suppliers assessed in the last 3 reference clip. This could include examples of the underlying
years: This refers to the number of entities across the calculations or approaches to data aggregation used to
different categories of business activities that have compile the provided quantitative information.
been assessed in the last three years, divided by the total
absolute number of entities within the different categories of
References
business activities in the current year. If an entity has been
assessed multiple times in the last three years, it should only Office of the High Commissioner for Human Rights:
be counted once. https://www.ohchr.org/Documents/Publications/GuidingPrin
ciplesBusinessHR_EN.pdf
Data Requirements
Business & Human Rights Resource Center:
For information on their own operations, companies may
https://www.business-humanrights.org/en/big-issues/un-
choose the basis for reporting from the following options: %
guiding-principles-on-business-human-rights/
of FTEs, % of revenues, % of clients, % of investment
portfolio, % of sites or % of products.
For information on contractors and Tier I suppliers, the basis CSRD - S1-2 AR 25 e, S1-4 AR 35, S2-1 19 AR 14, S2-4 36, S2-
for reporting should be the % of contractors and Tier I 4 AR 30, S3-4 AR 27
suppliers. GRI Disclosure - 408-1, 414-2
SFDR Principal Adverse Impacts - Human Rights
For information on joint ventures, the basis for reporting UNGP - A2
should be the % of joint ventures. WEF Metrics - Human rights review, grievance impact and
modern slavery (#, %)
Supporting evidence: No document is required to support
your response. You may still provide a reference using the
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Human Rights Mitigation & Remediation
Assessment Focus
Question Rationale In assessing human rights impacts, companies will have

search for both actual and potential adverse impacts.
The purpose of this question is to know through concrete
Potential impacts should be prevented or mitigated through
examples, what the reporting company has done during the
the horizontal integration of findings across the business
reporting period to reduce the likelihood of negative impacts
enterprise, while actual impacts those that have already
related to each human rights risk and what actions has it
occurred should be a subject for remediation.
taken when the impact has already happened.
Question Layout
Does the company have measures to mitigate and remediate the negative impacts of human rights risks and is it available publicly?
□ Yes, the company has measures to mitigate and remediate negative impacts of human rights risks. Please indicate where
this information is available in public reporting or corporate website.
□ Processes implemented to mitigate human rights risks
□ The number of sites with mitigation plans
□ The type of remediation actions taken

of social audits, where the concept includes and typically
Mitigation actions: The mitigation of a negative human rights
focuses on forward-looking actions to prevent a non-
impact refers to actions taken to reduce the extent of the
compliance from recurring.
impact. The mitigation of a human rights risk refers to actions
taken to reduce the likelihood that a potential negative
Data Requirements
impact will occur.
Information should be specifically related to human rights
Remediation actions: Here they are understood as processes issues, general information on ESG or sustainability would
that apply when the company has caused or contributed to a not be accepted unless it concretely states the specific
negative human rights impact (an actual violation has already human rights topics considered within a more general
happened) and through which it is able to help ensure that the approach.
people who were impacted receive an effective remedy. The
remediating action aims to restore individuals or groups that We require supporting evidence to be available in the public
domain.
they would have been in had the impact not occurred. Where
this is not possible, it can involve compensation or other Note: For the number of sites with mitigation plans,
forms of remedy that try to make amends for the harm information on the general number of mitigation plans or
caused. These outcomes may take a range of forms such as number of mitigation plans for operations/business
apologies, restitution, rehabilitation, financial or non- units/business operations/products/investment
financial compensation, and punitive sanctions (whether portfolio/clients will also be accepted.
criminal or administrative, such as fines), as well as the
prevention of harm through, for example, injunctions or For remediation actions, in case the company has been
guarantees of non-repetition. involved directly or indirectly in a human rights impact,
information should be provided on the type of remediation
actions taken. The information should always be linked with
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an existing impact or violation. In case the company has not relationship to remediate the harm and about its participation
caused nor contributed to any human rights violation, this in dialogue or mediation processes regarding the remediation
should be stated in the public domain. In this case, the option of the adverse impact is expected. Also, information about
can be ticked as no remediating actions would be expected. co-operation with judicial and non-judicial mechanisms
would be expected for companies involved in judicial or non-
Note for companies in BNK, FBN, INS:
judicial proceedings related to human rights issues. Besides,
Number of sites:
an entity acknowledging the harm suffered and
The number of sites can be interpreted as the number of
demonstrating efforts to improve its processes to ensure that
portfolios, client relationships or products with mitigation
similar adverse impacts will not reoccur is also acceptable.
actions in place.
In addition, information on direct mitigation and remediation

Mitigation actions:
actions is expected when the company has directly caused or
The following types of mitigation actions could also be
may have caused an adverse human rights impact.
considered when they specifically refer to human rights in
case of indirect involvement in a potential adverse human
rights impact: References
• specific human rights requirements in investment
Doing business with respect for human rights, A guidance tool
mandates or clear human rights conditions
for companies, 2nd edition, 2016, Shift, Global Compact
precedent to investments,
Network Netherlands, Oxfam.
• due diligence requirements with respect to investee
https://www.businessrespecthumanrights.org/image/2016/1
companies,
0/24/business_respect_human_rights_full.pdf
• use of leverage in case of investee company breach
of covenants,
• exclusions (maintaining a no-go list) of high-risk Standards & frameworks
companies or companies that are in
CSRD - S1-1 20c, S1-2 AR 25 e, S1-3 32a, S1-4 37, S1-4 40a
breach/violation of human rights principles,
AR 44-AR 45, AR 47, S2-1 17c, S2-3 27a AR 21, S2-4 34a AR
• active engagement with investee,
40-41,AR 43, S3-1 16c, S4-1 16(c)
• divestment decisions.
GRI Disclosure - 407-1, 408-1, 409-1, 411-1
IRIS+ - OI9077
Remediation actions:
SFDR Principal Adverse Impacts - Number of identified cases
As for remediation actions, companies within the BNK, FBN
of severe human rights issues and incidents
and INS would frequently only be indirectly linked with the
UNGC Questionnaire - HR7, HR8, L11, L3
adverse impact. In those cases, where the company has not
UNGP - A2.5, C3.2, C4.3, C6
contributed to the impact, but is still linked to the harm
through its business relationships, information about the
efforts to persuade the investee company/business
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Human Capital Management
Human capital can make up a significant part of a company's developing their human capital and make sure that their
intangible assets and for many industries, human capital employees have the necessary skill set needed to perform
development is one of the most financially material well and execute the business strategy. To address the skills
sustainability factors. Considering the drivers in gap challenge, companies must carefully consider their
technological disruption and innovation, demographic shifts, investments in training, upskilling, and reskilling their
and societal developments, companies need to focus on workforce.
Training & Development Inputs
Assessment Focus
Question Rationale
To address the skills gap challenge and remain competitive in costs and a more engaged and committed workforce. This
attracting and retaining talents, companies must carefully question assesses whether companies are leveraging their
assess their investments in training, upskilling, and reskilling current workforce capabilities by investing in their training &
their workforce. Training & development can lead to positive development, and whether these investments are made fairly
outcomes such as reduced turnover, reduced external hiring across the entire employee base.
Question Layout
Please fill out the following table for the related training & development data for the last fiscal year and attach supporting evidence of
where this information is reported.
□ Please indicate the percentage of global FTEs the data in the table below represents:
FY 2023
Average hours per FTE of training and development
□ This data is publicly available. Please provide supporting evidence or web
link:
Average amount spent per FTE on training and development.
□ This data is publicly available. Please provide supporting evidence or web
link:
Data breakdown
We break down the data for either of the KPIs above based on the following categories. Please select any that apply and attach
supporting evidence:
□ Age group
□ Gender
□ Management level (e.g., junior/low level, middle, senior/top level management)
□ Race, ethnicity, nationality, country of origin, cultural background
□ Type of training
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FTEs: Full-Time Equivalents is the number of working hours
that represents one full-time employee during a fixed time
period, such as one month or one year. The concept is used to but could answer the question with a larger
convert the hours worked by several part-time employees into coverage that it is only privately available (e.g., for
the hours worked by full-time employees. 100% of FTEs), the company should fill out the
question only based on the information publicly
Average hours of training and development per FTE: it refers reported and hence verifiable.
to the total number of hours of training and development
provided in the last fiscal year divided by the total number of Data breakdown
FTEs. • Companies can provide data breakdown for either of
the two KPIs asked, i.e.,
Average amount spent on training and development per
FTE: it refers to the total amount spent on training and on training and development programs
development in the last fiscal year divided by the total • We do not expect companies to break down the data by
all the categories mentioned in the question, but full
points for this section will be granted for having a
employee salaries. breakdown for at least 2 categories. The purpose of this
section is to assess whether companies can track
By type of training: Here different types of training may these KPIs in a way that allow them to evaluate and
-the- reassure fair treatment of all employees.
mentorship, leadership trainings, compliance trainings, • In Europe, according to the Article 9 of the GDPR, it is
cultural diversity training, IT training, OHS training etc. prohibited to process personal data revealing racial or
ethnic origin, except if the data subject has given
explicit consent to the processing of those personal
Data Requirements
data, provided this is not prohibited by national law.
Please note: If you have 25 or less FTEs in your organization, Other exemptions exist, such as reasons of substantial
then please mark the question as Not Applicable . public interest which might include statistical research
purposes for equality of opportunity and treatment. We
Disclosure Requirements therefore expect companies to report on only two
different categories, to not penalize companies that do
• Additional credit will be granted for relevant not report data breakdown on race.
publicly available evidence covering the following • For this section, companies can attach either private or
public evidence and we expect to see the specific data
s broken down by these categories e.g.,
nior employees,
• Difference in coverage of the different KPIs: This y% for mid-level managers and z% for senior managers
question asks for two different KPIs. In case the
reporting coverage of this KPIs is different e.g., a
company can p
CSRD - S1-13 83b AR 78
ESG Disclosure Standards (China) - S.1.2.1 Democratic
reasons, the management of employees, S.1.4.2 Employee training
company should provide data for both KPI for 30% GRI Disclosure - 404-1
of their FTEs. IRIS+ - OI7390, OI7877
• Difference between publicly and privately available WEF Metrics - Training provided (#)
data: Companies should report information in line
with their public reporting. That means in case a
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Employee Development Programs
Assessment Focus
Question Rationale
One of the challenges companies' faces is to fully understand their benefits to the business, and asking whether companies
the positive business and financial effects of investing in are able to quantify these benefits. For investors,
employees and whether the investments they are making are understanding whether companies are maximizing the
having the desired impact on their people and their benefits of their investments in people can be key to
organizations. This question measures how and to what understanding how efficiently capital is deployed across the
degree companies can measure the benefits to their business organization and how companies are making forward looking,
of their investments in human capital by describing two strategic investments in their people.
examples of employee development programs, demonstrating
Question Layout
Does your company have employee development programs that have been developed to upgrade and improve employee skills? Please
indicate where this information is available in your public reporting or corporate website.
For further clarifications on the information asked below, please consult the information text.
□ Yes, We have employee development programs that have been developed to upgrade and improve employee skills and are
publicly available.
Program 1 Program 2
Name & Description of the program □ Please provide description of □ Please provide description of
the program the program
Business benefits of the program □ Please provide business □ Please provide business
benefits of the program benefits of the program
Quantitative impact of business □ Please provide quantitative □ Please provide quantitative

benefits (monetary or non-monetary) impact of business benefits: impact of business benefits:
% of FTEs participating in the program
Supporting Evidence

Employee development programs: these refers to programs OHS or workplace security training, board training for new
that have been developed to enhance or improve your board members, training programs that are necessary to
bring new employees up to a minimum standard in order to
job-trainings such as leadership or management fulfil their job requirements, graduate/ trainee or
development programs, young talent development programs, apprenticeship programs.
sales training for sales executives, green or black belt
certifications, project management training etc. This does not Name & Description of the program: companies are expected
cover programs providing employees with the basic skills they to provide specific example of programs and explain how they
need to carry out their daily work or to help them reach can provide business benefit. General reference to the
certain minimum requirements, such as mandatory existing of a Learning Academy or Institute or purchase of
compliance training, annual recertification programs, basic LinkedIn Learning license is not sufficient.
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• Companies should select the programs they will
Description of program objective/business benefits: it refers report on based on their strategic importance.
to the benefits that the company derives as a result of Companies should select programs that can
providing the training, not the benefits for the employee sufficiently demonstrate their business impact than
undertaking the training. Of course, programs may result in select the programs that have simply higher
benefits to both the company and the employees. This should
not be a description of the employee development program
but rather an explanation of how the program aids the therefore greater values of employee coverage will
not necessarily lead to a better scoring performance
targets. for this question.
• Quantitative impact of business benefits: The
Quantitative impact of business benefits: they refer to either quantitative impact reported should be linked to the
monetary or non-monetary metrics that a company uses to
track and measure the impacts of its development programs. previous field and not unrelated.
These metrics should be linked to the employee development • Supporting Evidence: Please share a public
program described in terms of a measurable outcome as a document or weblink and indicate the relevant page
relevant indicator of more effective business performance. where the information related to selected programs
Examples include but are not limited to quantitative are described.
information showing changes in employee engagement,
employee turnover, efficiency, productivity, revenue
generation cost savings, sales, internal employee promotions,
employee retention etc. (i.e., specific statements of x% • The public document(s) or weblink(s) you attached
increase in employee engagement, x% decrease in employee will be used to verify the qualitative part of your
turnover etc.) This does not refer to the number of trainees/ response. Any qualitative response that cannot be
participants or any qualitative description of the verified in the attached public document(s) will
beforementioned metrics (i.e., not be accepted.
number of trainees • Quantitative figures provided in the response also
etc.) require public supporting evidence. This could
FTEs: Full-Time Equivalents is the number of working hours approaches to data aggregation used to compile
that represents one full-time employee during a fixed time the provided quantitative information..
period, such as one month or one year. The concept is used to
convert the hours worked by several part-time employees into Please note: If you have 25 or less FTEs in your organization,
the hours worked by full-time employees. then please mark the question as Not applicable .
Percentage of FTEs participating in the program: it refers to Standards & frameworks

percentage of FTEs actively participating/ made use of the
program, not the number of people that are eligible or have CSRD - S1-1 AR 17 h)
access to the program, out of the total amount of FTEs in the ESG Disclosure Standards (China) - S.1.2.1 Democratic
latest reporting year. management of employees

IRIS+ - OI3368
WEF Metrics - Monetized Impacts of Training - Increased
Data Requirements earning capacity as a result of training intervention (%, $)
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Human Capital Return on Investment
Assessment Focus
Question Rationale
The Human Capital Return on Investment provides a means of operating profitability. This metric provides a view into the
measuring a profitability in relation to total degree to which economic value is derived looking at
employee costs. It is derived by removing non-employee costs profitability solely in relation to human capital costs.
from overall operating costs and deriving the resulting
Question Layout
Does the company publicly report the following information on a standard human capital return on investment metric, serving as a
global measure of the return of the Human Capital programs.
□ Yes, the company publicly reports on the following human capital return on investment metrics. Please indicate where the
FY 2020 FY 2021 FY 2022 FY 2023
a) Total Revenue, as specified in the "Denominator" question
Currency:
b) Total Operating Expenses
Currency:
c) Total employee-related expenses (salaries + benefits)
Currency:
Resulting HC ROI (a - (b-c))/c
Total Employees, as specified in the "Denominator" question

in relation to the total human capital expenses.
Total Revenue: it refers to the amount your company has
received in revenues before any deductions are made.
Total operating expenses: it refers to all the expenses your public domain. The information provided has to be
company has from its operations. It should be in line with included in your public reporting (e.g. annual report,
accepted financial accounting and reporting standards, sustainability report, integrated report, company
including everything a company will have defined in its publications, separate fuel efficiency strategy
income statement. document) or corporate website.
Total employee-related expenses (salaries + benefits): this public document(s) will not be accepted.
includes training and development programs, pensions,
hiring, etc., as it covers all costs related to employees. Please note:
• If you have 25 or less FTEs in your organization,
Data Requirements then please mark the entire criterion as 'Not

applicable'.
• By subtracting Total Operating Expenses (b) less Total • If you have 26-100FTEs, then also this
employee-related expenses (salaries + benefits) (c) question will be marked as NAP.
from Total Revenue profitability
prior to human capital costs is calculated. Dividing
this figure by Total employee-related GRI Disclosure - 201-1
expenses (salaries + benefits) (c) then leads to the ratio IRIS+ - FP1001, FP4831
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WEF Metrics - Economic contribution, Monetized Impacts of
Training - Increased earning capacity as a result of training
intervention (%, $)
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Hiring
Assessment Focus
Question Rationale
Employees are one of the most important intangible assets Companies need to build organized internal career mobility
for companies. The ability to attract qualified and talented processes to retain talents and reduce external hiring costs.
employees, as well as retain and nurture internal talents is This question asks for the number of new employee hires, the
pivotal for corporate success. Companies focused on percentages of positions filled by internal candidates, the
attracting the best talents should not forget about their hiring cost, and data breakdown by age, gender, race/
internal talents who have grown with the company, ethnicity, and management level.
understand the organization, its mission and culture.
Question Layout
Please indicate the total number of new employee hire rates and the percentage of open positions filled by internal candidates.
Please also report the average hiring cost/FTE for the last fiscal year.
Please note: The average hiring cost/FTE should specifically relate to the number of employees hired last year, not average cost for
all employees.
FY 2020 FY 2021 FY 2022 FY 2023

Total number of new employee hires
□ This data is publicly available.
Please provide supporting
evidence or web link:
Percentage of open positions filled by

internal candidates (internal hires)
Please provide supporting
evidence or web link:
Average hiring cost/FTE

Currency:
Data breakdown
We break down the new employee hires and/or internal hires data based on the following categories. Please provide supporting
evidence:
□ Age group
□ Gender
□ Management level (e.g. junior/low level, middle, senior/top level management)
□ Race, ethnicity, nationality, country of origin or cultural background
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Question-Specific Guidance & Definitions data from the fiscal year 2019 is being prefilled in all 4 years
FTEs: Full-Time Equivalents is the number of working hours

Please make
that represents one full-time employee during a fixed time
sure to review the prefilled data and update it accordingly for
period, such as one month or one year. The concept is used to
each fiscal year. Duplicated data which is not supported by an
convert the hours worked by several part-time employees into
explanation in the comment box will be removed.
the hours worked by full-time employees.
Data breakdown:
Total number of new employee hires: refers to the number of
•
new full-time equivalents (FTEs) hired in the reporting year. It
by all the categories mentioned in the question, but
should not include internal candidates i.e. existing employees
full points will be granted for this section for having
that have been hired in different positions or internally
a breakdown for at least 2 categories. The purpose
promoted.
of this section is to assess whether companies are
able to track these metrics in a way to be able to
Percentage of open positions filled by internal candidates (or
evaluate and reassure fair treatment of all
internal hires or promotions): refers to the total number of
employees.
• In Europe, according to the Article 9 of the GDPR,
by the total number of vacancies in the company in the
it is prohibited to process personal data revealing
reporting year. This metric provides a mean of determining
racial or ethnic origin, except if the data subject has
the effectiveness of human capital development by providing
given explicit consent to the processing of those
employees with the skills required for promotion, and it also
personal data, provided this is not prohibited by
demonstrates how proactive organizations are in providing
national law. Other exemptions exist, such as
their employees with new challenges for growth and
reasons of substantial public interest which might
development throughout their careers.
include statistical research purposes for equality of
opportunity and treatment. We therefore expect
Average hiring cost/FTE: refers to the average cost of hiring a
companies to report on only two different
new full-time equivalent (FTE) in the reporting year. This
categories, in order to not penalize companies that
figure should be calculated based on the costs of hiring all
do not report data breakdown on race.
new FTEs in the reporting period and not based on the costs
• For this section, companies can attach either
of hiring FTEs who were already at the company before the
private or public evidence and we expect to see the
last fiscal year started. The average hiring cost includes
specific quantitative data broken down by these
internal and external recruiting cost e.g. recruiter salaries,
categories
interviews, agency fees, advertising, job fairs, travel and
relocation costs.
Please note: If you have 25 or less FTEs in your organization,
then please mark the question as Not applicable
Additional credit will be granted for relevant publicly available Standards & frameworks
evidence covering the following aspect of this question, for at
EDCI - Organic Net New Hires, Total Net New Hires
least the most recent reported year.
ESG Disclosure Standards (China) - S.1.4.3 Employee career
• Total number of new employee hires
planning and position change support
• Percentage of open positions filled by internal
candidates (internal hires)
IRIS+ - OI3547, OI5479, OI8251
WEF Metrics - Absolute number and rate of employment
IMPORTANT if you are prefilling data from previous
assessments: Please note that for technical reasons, the
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Type of Performance Appraisal
Assessment Focus
Question Rationale
The purpose of this question is to assess the various methods management and to the development of human capital within
that companies use to measure performance and how often the organization. Regular performance and career
performance appraisals take place. This aids the personal development reviews can also enhance employee
development of individual employees and ensures a holistic satisfaction, which correlates with improved business
approach to team management. It also contributes to skills performance
Question Layout
Does the company conduct individual and/or team-based performance management appraisals and is this information available
publicly?
Yes, the company has individual and/or team-based performance management appraisals. Please indicate where this information is
□ Management by objectives
□ Multidimensional performance appraisal (e.g. 360 degree feedback)
□ Team-based performance appraisal
□ Agile conversations
Performance Appraisal Frequency:
Please indicate the frequency at which performance appraisals take place, for at least one type of performance appraisal
□ Ongoing
□ Quarterly/Twice a year
□ At least yearly
□ Not reported
Question-Specific Guidance & Definitions performance is provided and/or receiving client or external
feedback.
Employees: Refers to full-time and part-time employees.
Team-based performance appraisal: Refers to a system

Management by objectives: Refers to a systematic process in
where employees are assessed as part of a
which employees have pre-defined and measurable goals
team rather than only as individuals. It is likely that
that are set in a collaborative manner on at least a yearly
companies will use a two-pronged approach e.g. team goals
basis together with their line manager and routinely followed
up on.
to an individual review and team review.
Multidimensional performance appraisal: Refers to a system

Agile conversations: Agile performance management is an
i
unstructured approach to managing employee performance
variety of inputs, not just the targets set by a manager. This
and development throughout the year as opposed to on an
can include an assessment of how the employee meets the
annual or bi-annual basis. It is collaborative, involving regular
values and objectives of the department or company,
conversations and continuous feedback. Agile performance
receiving feedback from their peers, direct reports, and other
manageme
annual performance outcome or rating) it is more about the
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process of getting there, which involves regularly re- This question requires publicly available evidence covering
addressing objectives and barriers to effective performance. the following aspects of this question, for at least the most
recent reported year.
Ongoing • The type of performance appraisal.
conversation with a superior/manager/senior leader about • How often a type of performance appraisal was
professional development. These can be formal reviews and carried out
regular check-ins. We can also accept this if the company is
carrying them out for the first time but with the explicit Please note: If you have 25 or less FTEs in your organization,
intention of conducting them on an ongoing basis. then please mark the question as 'Not Applicable'.
Data Requirements
Supporting evidence can be provided to support your
response. This can be reference to an integrated report,
compensation and benefits
sustainability report or weblink.
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Long-Term Incentives for Employees
Assessment Focus
Question Rationale
Long-term incentive programs can be essential for companies question assesses the long-term incentive programs the
to retain well-qualified employees over time. Such programs company has in place, the time frame for which performance
serve to orient key decisions throughout the organization incentives are paid out, the extent to which these programs
around longer-term goals and strategic objectives, giving apply to employees across the organization, and the extent to
companies a greater likelihood of success over time. This which they are associated with sustainability principles.
Question Layout
Does your company provide long-term incentives for employees below the senior management level? Long-term incentive programs
are programs tied to an employee's performance. The performance can be measured during one or multiple years. These incentive
programs do not include employee benefits (please see the information button definitions for more information).
Please note: senior management includes employees that are at most two management levels from the CEO (or equivalent). Below
senior management level refers to all employees that are more than two management levels away from the CEO. If your company
uses a different definition for "below senior management level" please provide the definition in your answer.
Long-term incentives for the executive management and/or senior management are not accepted in this question.
Please describe the following Our long-term Please report the Do the long-term
aspects (both): incentives for percentage of incentives include
employees below the your workforce targets associated with
1) the type of long-term senior management below senior sustainability
incentive program (e.g. stock level are on average management performance? Please
options, restricted stock Public paid out after: level (max. two explain in the comment
units, cash incentives, etc.); Reporting levels from the box below:
CEO) that this
2) the type of employees program applies
below the senior management to:
level the program applies to:
□ Please provide □ Description □ 2 years □ Please provide
relevant information Publicly □ 3 years % of our relevant
below:: available □ Longer than 3 employees information
years below:

Long-term incentives: Variable compensation that is tied to should not be included as these are not linked to employee
the performance of an employee. The performance can be performance.
measured during one or multiple years. This can include
deferred cash bonuses, stock options and restricted stock Sustainability performance: It can relate to any sustainability
units. Employee benefits, such as pension contributions goals set by your company, whether they are related to
(whether mandatory or voluntary) or extra vacation days, environmental issues, social issues such as occupational
214 / 252
health and safety, or any other sustainability issue defined as
material by your company. Long-term incentives for executive management and/or
senior management are not accepted in this question.
Senior management level refers to employees that are within
Please note: If you have 25 or less FTEs in your organization,
then please mark the question as 'Not Applicable'.
below the "senior management level". Please note that the
definition of "senior management level" is up to the company
as we allow the company to choose the best definition
according to its business plan and company structure. If your Disclosure requirements for the partially public question:
definition differs from our definition due to your business Additional credit will be granted for the publicly disclosing
model, please explain this in the question. information on long-term incentive program offered to
employees below senior management level.
Data Requirements
Average time period for performance: The average pay-out
the qualitative part of your response. If a question
time period on which these incentive programs are based. If
text field is available, a comprehensive answer in
different pay-out time periods are used for different
that field can be accepted. Any qualitative response
employee categories, please use a weighted average of the
that cannot be verified in the attached document(s)
pay-out time periods for long-term incentive programs that
or via the information provided in the related
exist.
question text field (if available) will not be accepted.
• You may provide a reference using the reference
Percentage of your workforce below senior management
clip. This could include examples of the underlying
level (max. two levels from the CEO): Refers to the percentage
calculations or approaches to data aggregation
of employees that are not considered senior management
used to compile the provided quantitative
that are part of the long-term incentives program. For
information.
example, if your company has 100 employees, 10 are senior
management (a maximum of two level from the CEO in the
organizational structure) and 10 employees below senior Standards & Frameworks
management are part of the long-term incentives program, IRIS+ - OD4091
then 11% (=10/90*100) of employees below senior
management level are covered in the program.
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Employee Support Programs
Assessment Focus
Question Rationale
Employee health and well-being are essential to ensuring turnover. As a result, companies can improve their financial
employee satisfaction, productivity, and retention. While and non-financial performance indicators.
flexible work arrangements allow employees to adapt their
work schedule to their individual needs and personal
commitments, paid parental and care leave, as well as that aim to foster employee health & well-being. To reward
childcare facilities and lactation rooms, ensure that greater flexibility and equality for both caregivers, the
employees have the possibility to balance work and care question considers the % of parental leave for the non-
responsibilities. This flexibility and these benefits boost primary caregiver compared to the total number of weeks
employee morale, increase productivity, reduce absenteeism, provided for the primary caregiver.
and help to attract and retain top talent while reducing
Question Layout
Does the company -being in the following areas and are they
available publicly?
□ Yes, the company has employee support programs. Please indicate where this information is available in public reporting or
corporate website.
Employee Benefits
□ Workplace stress management
□ Sport & health initiatives
Work Conditions
□ Flexible working hours
□ Working-from-home arrangements
□ Part-time working options
Family Benefits
□ Childcare facilities or contributions
□ Breast-feeding/lactation facilities or benefits
□ Paid parental leave for the primary caregiver (please enter total number of paid leave in weeks offered to the majority of
your employees):
□ Paid parental leave for the non-primary caregiver (please enter total number of paid leave in weeks offered to the majority of
your employees):
□ Paid family or care leave beyond parental leave (care for a child, spouse, partner, dependent, parent, sibling, or other
designated relation with a physical or mental health condition)

Sport & health initiatives: This refers to programs or
Workplace stress management: This refers to programs,
initiatives that help promote overall health of employees
information, or trainings offered, targeted at helping
involving physical activity, mental wellbeing, and/or nutrition
employees manage their stress levels. This relates to both
goals. Such programs could include onsite fitness facilities,
work and non-work-related stress. Examples of workplace
virtual exercise classes, fitness tracking and biometrics, or
stress management programs include, for example,
gym reimbursement.
meditation classes, mental health benefit programs, and
other wellness programs or education that aim to help
Flexible working hours: This refers to a schedule which allows
employees reduce stress and improve mental wellbeing in the
employees to decide when to start and/or finish their workday
workplace.
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according to their individual needs. Flexible working hours
may give the employee total freedom over their working Paid parental leave for the non-primary caregiver: This refers
schedule or may require employee presence for a core set of to paid leave which is offered on top of normal paid vacation
hours in the day/week and manage the rest of their working time to specifically support non-primary caregivers during
hours as best suits them. pregnancy, after birth or for the adoption or fostering of a
child. This paid leave is separate from other types of leave
Working-from-home arrangements: This refers to a working such as sick leave or paid time off. A non-primary caregiver is
arrangement by which employees can work from their own a person with parental responsibility for a child but does not
homes or other locations of their choice outside of the have primary responsibility for the care and upbringing of the
company facilities. child.
Part-time work: Part-time work is a form of employment by Paid family or care leave beyond parental leave: This refers to
which the employee works fewer hours in the week than what paid leave granted to the employee to take care of a spouse,
is deemed a full-time employment. domestic partner, child, dependent, parent, parent-in-law,
grandparent, grandchild, sibling, or other designated relation
Childcare facilities: This refers to on-site childcare centres or when this person has a physical or mental health condition
services which allow parents to drop-off their children to which requires additional care. This is separate from paid
qualified caregivers during their working hours. parental leave which is granted to parents which have a new
child.
Childcare contributions: This refers to financial support
provided to parents specifically designed to ensure that they
have access to qualified childcare services to take care of Data Requirements
their children during working hours. Disclosure requirements for public questions: Supporting
evidence available in the public domain is required for each
Breast-feeding/lactation facilities: This refers to a dedicated aspect of this question.
lactation room or facility so that new mothers can breast-
feed or breast-pump for their new-born child. This space Please note: If you have 25 or less FTEs in your organization,
should be located at the workplace and offer privacy, then please mark the question as 'Not Applicable'.
comfort, storage, and hygiene.
References
Breast-feeding/lactation benefits: This refers to benefits
provided to new mothers to ensure they have capacity and Well Certification C08, C09 and C10
support to allow them to breast-feed or breast-pump for their
new-born child at work. These benefits include, but are not
limited to, paid break times for feeding or pumping (15-20
minutes every 2-3 hours depending on individual needs), ESG Disclosure Standards (China) - S.1.3.4 Employee mental
subsidies for the purchase of portable breast-feeding or health assistance
breast-pumping equipment. GRI Disclosure - 401-2
IRIS+ - OI5102, OI7983
Paid parental leave for the primary caregiver: This refers to SASB - HC-DY-330a.2
paid leave which is offered on top of normal paid vacation WEF Metrics - Health and safety (%)
time to specifically support primary caregivers during
pregnancy, after birth or for the adoption or fostering of a
child. This paid leave is separate from other types of leave
such as sick leave or paid time off. The primary caregiver is
the person primarily responsible for the care and upbringing
of a child.
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Employee Turnover Rate
Assessment Focus
Question Rationale
People are one of the main drivers of corporate growth and uncertainty or dissatisfaction among employees or structural
play an essential role in the successful execution of organizational changes. High turnover may impact employee
productivity and lead to increased costs due to higher
and voluntary turnover. Total turnover may fluctuate and expenses for employee recruitment. Finally, it is very
reflect industry trends or economic cycles. Voluntary turnover important to evaluate turnover patterns by age, gender or
other employee groups as this can be an indication of
its employees. This indicator may reflect high levels of incompatibility or potential inequity in the workplace.
Question Layout
Please indicate your company's total and voluntary turnover rates for the last four years as a percentage of total number of
employees in the table below.
FY 2020 FY 2021 FY 2022 FY 2023

Total employee turnover rate
□ This data is publicly
available. Please
provide supporting
evidence:
Voluntary employee turnover
rate
□ This data is publicly
available. Please
provide supporting
evidence:
Data coverage (as % of all FTEs
globally)
Data breakdown
We break down the data of the total employee turnover rate based on the following categories. Please provide supporting evidence:
□ Age group
□ Gender
□ Management level (e.g. junior/low level, middle, senior/top level management)
□ Race, ethnicity, nationality, country of origin or cultural background
Question-Specific Guidance & Definition

Total employee turnover: Refers to the proportion of Voluntary employee turnover and the involuntary employee
employees who leave an organization over a set period (often turnover rate.
a year), expressed as a percentage of the total employees. Voluntary employee turnover: Refers to the proportion of
The figure should be calculated using the total number of employees who choose to leave an organization (such as
employees at the end of the latest reporting year. Total resignation, retirement, early retirement etc.) over a set
employee turnover rate number should be the sum of the period (often a year), expressed as a percentage of the total
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employees. The figure should be calculated using the total racial or ethnic origin, except if the data subject has
number of employees at the end of the latest reporting year. given explicit consent to the processing of those
personal data, provided this is not prohibited by
national law. Other exemptions exist, such as
Data Requirements reasons of substantial public interest which might
• include statistical research purposes for equality of
they outsource all their activities to contractors, opportunity and treatment. We therefore expect
then contractors are to be considered employees companies to report on only two different
and the question will be applicable. categories, in order to not penalize companies that
• If the company's definition for the turnover rates do not report data breakdown on race.
does not match our definition, then mark 'Not • For this section, companies can attach either
Applicable' for this question private or public evidence and we expect to see the
specific quantitative data broken down by these
Disclosure requirements: Additional credit will be granted for categories
relevant publicly available evidence covering the following

aspects of this question, for at least the most recent reported Please note: If you have 25 or less FTEs in your organization,
year. then please mark the question as 'Not Applicable'.
• Total employee turnover rate

• Voluntary employee turnover rate Standards & frameworks
CSRD - S1-6 50c AR 59
Data Breakdown:
EDCI - Annual Percent Attrition
•
by all the categories mentioned in the question, but
turnover rate
full points will be granted for this section for having
a breakdown for at least 2 categories. The purpose
IRIS+ - OI1150, OI1638, OI3653, OI4499, OI8431
of this section is to assess whether companies are
SASB - CG-EC-330a.2, FB-RN-310a.1, HC-BP-330a.2, HC-DY-
able to track these metrics in a way to be able to
330a.1, SV-HL-310a.1, SV-PS-330a.2, TR-RO-320a.2
evaluate and ensure fair treatment of all employees.
WEF Metrics - Absolute number and rate of employment
• In Europe, according to the Article 9 of the GDPR, it
is prohibited to process personal data revealing
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Trend of Employee Wellbeing
Assessment Focus
Question Rationale
Employee engagement, satisfaction and wellbeing surveys The four aspects Job satisfaction, Purpose, Happiness and
are crucial tools for evaluating employee conditions and Stress have been recommended by the World Wellbeing
developing policies to attract, retain and develop the best Movement as evidence-informed employee wellbeing
employees and identify areas for improvement. In this
question, we determine whether companies conduct Wellbeing Research Centre. They capture the complimentary
employee surveys and in how far metrics on Job satisfaction, dimensions of wellbeing and business outcomes such as
Purpose, Happiness and stress are addressed in the employee productivity, retention, recruitment and firm
employee surveys performance.
Question Layout
Please indicate if your company conducts an employee survey.
□ Yes, we conduct an annual employee survey
Please indicate in the following table the percentage of employees that are for example highly engaged, with highly positive
experience or a high level of wellbeing as found through your company's scaled employee surveys. Please select only the core focus of
your survey as well as its coverage. Please note: If your company only conducts its primary employee survey every two years, please
duplicate the value of the previous year in the table and provide the target for the most recent year the primary survey was conducted.
Core Focus Unit FY 2020 FY 2021 FY 2022 FY 2023 What was your
target for FY
2023?
% of employees with
top level of
engagement,
satisfaction, wellbeing,
or employee net
promoter score (eNPS)
Data coverage % of employees

who responded
to the survey
Public Reporting
□ The results of our annual employee surveys are publicly available. Please provide supporting evidence or web link.
In tracking employee metrics, which of the following aspects are addressed in your employee surveys (select all that apply). Please
provide supporting evidence.
□ Job satisfaction ( external motivation e.g., I am satisfied with my job)

□ Purpose (internal motivation, e.g., my work has a clear sense of purpose)
□ Happiness (e.g., I feel happy at work most of the time)
□ Stress (e.g., I feel stressed at work most of the ti
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Employee Satisfaction: Refers to external motivation. How
happy employees feel about their job; specifically concerning
Top level engagement or score: The top level based on a external incentives such as employment benefits.
-10 on
a 10 point scale, or equivalent. While companies might Employee Net Promoter Score (eNPS): Refers to the
conduct multiple surveys, in this question we ask for the top -10, how likely are you to recommend
level engagement or score only on the core focus of the
survey. Depending on the core focus of the survey, top level which fall in between 9-10 are considered promoters or a
can refer to the highest category of either engagement,
satisfaction, well-being, or top level of employee Net Those who fall between 7-8 are passives or employees who
Promoter Score (eNPS). are neutral, or generally content but not fully committed to
the organization. Employees who answer between 0-6 are
% Of employee survey respondents: Refers to the
percentage of FTE employees who responded to the survey. your company and are unhappy and disengaged to varying
This should not be the percentage of employees invited to degrees.
participate in the survey.
Aspects addressed in employee surveys: The four aspects
Target: Targets can be the precise, stated target for the year included in the question involve metrics related to the
in which the survey was conducted, or if the target is long- complementary dimensions of wellbeing at work as
term for a specific future year, it can be linearly extrapolated. experienced by the employee. They align with how statistical
For instance, if the company reported 70% of employees were agencies are measuring general wellbeing and how Indeed
engaged or satisfied in FY2015, and set a two-year target of surveys workplace wellbeing.
reaching 80% by FY2017, the linearly extrapolated target for • Job satisfaction: Refers to questions in the survey
FY2016 would be 75% (e.g. 10% improvement divided by two aiming at measuring evaluative wellbeing (e.g. "I
years equals 5% per year) feel completely satisfied with my work")
• Purpose: Refers to questions in the survey aiming
Employee Engagement: definitions of employee engagement at measuring eudemonic wellbeing (e.g "My work
may vary, but the following are representative: has a clear sense of purpose")
• Happiness: Refers to questions in the survey
• Gallup: Those who are involved in, enthusiastic aiming at measuring positive affect (e.g. "I feel
about, and committed to their work and workplace. happy at work, most of the time"
• Utrecht Work Engagement Scale (UWES-9) • Stress: Refers to questions in the survey aiming at
positive, fulfilling, work-related state of mind that is measuring negative affect (e.g "I feel stressed at
work, most of the time")
• Grovo:
Data Requirements
cares about the quality of their work. Personal
because the work and its contribution to the • If your company only conducts an employee survey
success of company matters to the employee. And every two years, please duplicate the value of the
previous year in the table and provide the target for
delivering a quality that will reward their investment the most recent year a survey was conducted
• For the employee metric aspects section of the
question, companies can attach either private or
Employee Wellbeing: Gallup public evidence, however only information that can
things that are important to each of us and how we be verified will be accepted.
experience our lives. Key wellbeing measures include how
employees rate their current and expected future lives (life Disclosure requirements for partially public question:
evaluation) and how strongly employees believe their Additional credit will be granted for relevant publicly available
• The results of annual employee survey (i.e., the % of
employees with top level of engagement,
satisfaction, wellbeing, or employee net promoter
score (NPS) figure for at least the most recent
reported year).
Please note:
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• If you have 25 or less FTEs in your organization, then ESG Disclosure Standards (China) - S.1.2.5 Employee
please mark the question as 'Not Applicable'. satisfaction survey
• If you have 26-100 FTEs, then also this question will IRIS+ - OD4091
SASB - CG-EC-330a.1, SV-PS-330a.3, TC-IM-330a.2, TC-SI-
330a.2

EDCI - % employees responding to survey, Do you conduct an
annual employee survey?
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Customer Relations
Strong relationships with customers lead to increased present on several platforms to reach out to customers, and
customer loyalty. Harvard Business School research revealed for some sectors today it is strategic development to develop
that a 5% increase in retention can result in a profit increase strong online capabilities. In some industries, customer data
of up to 75%, depending on the industry. The value of privacy and safety risks have emerged and companies need to
retaining customers makes perfect business sense when one ensure strong policies to avoid increasing costs of breaches
considers that a consumer retained for life is more cost and negative reputational impact.
effective, requires less service, provides more business and
contributes to new customer acquisition by offering positive The key focus of the criterion is on the tools a company has
referrals. Additionally, customer relationship management implemented or is using to manage customers, online
tools provide important data which allows the company to strategy, sales and distribution channels, customer
target relevant customer groups, develop specific products, satisfaction and customer protection.
and ensure that it has all relevant information to strengthen
customer relationships. Online presence and channels have
reshaped customer relationships: companies need to be
Customer Satisfaction Measurement
Assessment Focus
Question Rationale
Research from Harvard Business School has shown that a 5% cost effective, requires less service, provides more business
increase in retention can result in a bottom-line profit and contributes to new customer acquisition by offering
increase of up to 75%, depending on the industry. The positive referrals. Companies in consumer-facing industries
dramatic economic power of customer retention is revealed (B2C) should therefore monitor customer satisfaction and
when viewing customers in terms of lifetime value (LTV). The report the results of satisfaction surveys targeting consumers
value of retaining customers makes perfect business sense (i.e. end users) of their products/services.
when one considers that a consumer retained for life is more
Question Layout
Does your company monitor and set quantitative targets to improve satisfaction and are targets and results communicated
externally? Please attach documents and indicate the coverage for the data provided. Please refer to the information button for
additional clarifications. For each row in the table, it is mandatory that the values provided are in the same unit.
□ Yes, we measure customer satisfaction using relevant units of measurement. Please attach supporting evidence.
Satisfaction Measurement Unit FY2020 FY2021 FY2022 FY2023 What was your target
for FY 2023?
Satisfaction measurement Satisfaction
measurement
methodology
Data coverage: percentage of:
Customers
Operations
Revenues
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Tenants
□ Information is available in the public domain

Bi-annual satisfaction surveys: if your company only
Customer or client: Buyer of services or goods from someone
conducts a customer satisfaction survey every two years,
else. In the context of this questionnaire, we focus on
then please copy the results from the previous year (when you
customers/client for B2B companies.
did conduct a survey) into the box for the following year (when
you did not conduct one). For example, if you conducted a
Consumer: User of a certain product or commodity. In the
survey in 2015 but not in 2016, copy the results from the 2015
field of economics, a consumer can either be a single person
survey in the 2016 box, so as to fill the entire table and make
or an entire organization using a certain type of service. In the
it possible to calculate a trend. (FY-2 FY0).
context of this questionnaire, we focus on consumers for B2C
companies.
Data Requirements question. Additional credit will be granted for relevant

publicly available evidence covering the following aspect of
• B2C companies should report the results of this question:
satisfaction surveys targeting consumers of their • Percentage of satisfied clients in the last reported year
products/services (i.e. end users of the (measured through a satisfaction survey or through an
products/services instead of the distributor/retailers alternative approach)
they sell their products through).
• B2B companies should report the results of
satisfaction surveys for their customers or clients Guidance for utilities (ELC, MUW, GAS)
(direct buyers of their products or services) In the case of a company that has only exposure to electricity
transmission and/or distribution, we expect to use this
In case your company is active in different business involving question to gather information about the satisfaction of the
B2C activities (consumers) and B2B (customers), please clients using the services provided by the company regardless
report the information corresponding to the business that of the income model. For instance we intend to capture
represents the highest share of your total revenue. information about the satisfaction of generators and
consumers requesting connection access to the
Unit: % of satisfied customers out of total number of infrastructure, generators and consumers participating in
customers responding to the survey markets operated by the company, participants in the
network planning process if is coordinated by the
The percentage should be calculated as follows: infrastructure operator, etc
Number of satisfied customers / Total number of customers
responding to the survey. Guidance for Real Estate Management & Development and
Equity REIT
Data Coverage: % of customers surveyed (both respondents If in the 'Denominator Area' question, business activity
and non-respondents) out of total customers
The data coverage should be calculated as follows:
Number of customers surveyed (both respondents and non- coverage. If this activity is not chosen, i.e., only the activities
respondents) / Total number of customers
Companies may report full coverage if a statistically
significant, representative sample of its customer base has companies to report
been surveyed.

Target: We require the absolute target for the most recent
reporting year. If your company has a multiple-year and/or CSRD - S4-2 20(d) AR 17
relative target, please extrapolate what the target value ESG Disclosure Standards (China) - S.2.3.1 Customer Service
would have to be for the last financial year to make sure you IRIS+ - OD4091, PI7163
of the target period.
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Occupational Health & Safety
Poor occupational health and safety (OHS) performance has a performance against industry benchmarks. Industry-specific
direct negative impact on labor costs through lower questions additionally focus on training, audits and
productivity. Moreover, it can also affect a company's transparency. Industries operating in areas where HIV/AIDS is
reputation, impact staff morale or increase operating costs widespread are also expected to support their employees and
through fines and other contingent liabilities. Our key minimize the risks of disruption to their business activities.
questions focus on Key Performance Indicators (KPIs) for a
company's own operations, and for its suppliers and their
OHS Policy
Assessment Focus
Question Rationale
The purpose of this question is to identify companies that and take actions to achieve the intended outcomes of the
have an active commitment towards occupational health and OHS management system.
safety in line with the most relevant international OHS
standards. The policy needs to be company-specific with a The commitments included in the policy are then reflected in
company-wide commitment and not just for a single site, the processes companies stablish to ensure a robust,
business unit, or project. credible, and reliable OHS management system. Therefore, an
OHS commitment is a previous and necessary step on what to
The OHS policy should cover a set of commitments that build further measures.
capture the long-term direction of the organization in terms
of health and safety. It sets the company approach to health The OHS policy should set the direction for effective health
and safety and establishes in a clear way what are the and safety management. Board members need to establish a
company expectations towards employees and other health and safety policy that is much more than a document
interested parties are.
its values and performance standards.
The OH&S policy provides an overall commitment, as well as a
necessary framework for the organization to set its objectives
Question Layout
Does the company have a policy or commitment on Occupational Health and Safety (OHS) and is it available publicly?
□ Yes, the company has a policy or commitment on occupational Health and Safety (OHS). Please indicate where this
□
supervision.
□ Compliance with relevant OHS international standards and regulations, voluntary programs and/or collective
agreements on OHS.
□
□ A commitment to continually improve the performance of the OHS management system.
□ Setting up prioritization and action plans.
□ Establishment of quantitative targets for improving OHS performance metrics.
□ Endorsement of the implementation of the OHS policy. Please select the highest endorsing decision-making body:
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Data Requirements
public reporting (e.g. annual report, sustainability report, CSRD - ESRS 2 MDR-P 65a, ESRS 2 MDR-P 65b, ESRS 2 MDR-
integrated report, company publications...) or corporate P 65c, S1-1 19, S1-1 23, S1-4 AR 35, S2-4 AR 30
website. ESG Disclosure Standards (China) - S.2.1.1 Production
standard management policies and measures
Please note: If you have 25 or less FTEs in your organization, GRI Disclosure - 2-23, 403-10, 403-8, 403-9
then please mark the question as N . IRIS+ - OD4091, OI4972, OI5102, OI8001
SASB - EM-EP-320a.2, EM-EP-530a.1, EM-MD-540a.4, EM-
References RM-530a.1, EM-SV-320a.2, EM-SV-530a.1, RT-CH-530a.1
ISO 45001 UNGC Questionnaire - G3, L1, L1.1, L2
ILO Occupational Safety and Health Convention, 1981 (No.
155)
226 / 252
OHS Programs
Assessment Focus
Question Rationale
Poor occupational health and safety (OHS) performance has a
direct negative impact on labor costs through lower The OH&S programs should cover a set of actions that ensure
productivity. Lower performance not only poses a threat to a robust, credible, and reliable OH&S management system. It
aims at providing tools to assess and improve performance in
increased operating costs in form of fines and other the prevention of workplace incidents and accidents via the
contingent liabilities. With this question, we aim to find out effective management of hazards and risks in the workplace.
how a company ensures effective management of health
risks/issues and to identify companies that have dedicated
programs to Occupational Health and Safety.
Question Layout
Does the company have a program on Occupational Health and Safety (OHS) and is it available publicly?
□ Yes, the company has a program on Occupational Health and Safety (OHS). Please indicate where this information is available
□ OHS risk and hazards assessments to identify what could cause harm in the workplace.
□ Prioritization and integration of action plans with quantified targets to address those risks.
□ Integration of actions to prepare for and respond to emergency situations.
□ Evaluation of progress in reducing/preventing health issues/risks against targets.
□ Internal inspections.
□ Independent external verification of health, safety and well-being: please provide name and standards used: (such as ISO
45001)
□ Procedures to investigate work-related injuries, ill health, diseases and incidents.
□ OHS training provided to employees and/or other relevant parties to raise awareness and reduce operational health &
safety incidents.
□ OHS criteria introduced in procurement and contractual requirements.
domain. The information provided has to be included in your CSRD - ESRS 2 MDR-P 65d, S1-1 23, S1-14 AR 81, S1-4 AR 35,
public reporting (e.g. annual report, sustainability report, S2-4 AR 30
integrated report, company publications..) or corporate ESG Disclosure Standards (China) - S.1.3.1 Employee
website. occupational health and safety management, S.1.3.2
Employee safety risk prevention and control, S.1.3.3
Please note: If you have 25 or less FTEs in your organization, Response to safety accidents and work-related injuries
then please mark the question as Not Applicable. GRI Disclosure - 14.15, 403-10, 403-2, 403-5, 403-8, 403-9
SASB - EM-CO-320a.2, EM-EP-320a.1, EM-EP-320a.2, EM-
MD-540a.4, EM-RM-320a.2, EM-SV-320a.1, EM-SV-320a.2,
References
RR-FC-320a.2, RT-CH-320a.2
ISO 45001 UNGC Questionnaire - L3, L4, L5
ILO Occupational Safety and Health Convention, 1981 (No.
155)
227 / 252
Fatalities
Assessment Focus
Question Rationale
Keeping track of work-related injuries and fatalities should cover a company's entire operations, covering both internal employees
and external contractors. This is crucial for ensuring that legal requirements are met, that problematic and/or dangerous operations
can be identified and that safety measures can be improved.
Question Layout
Please complete the following table with the number of work-related fatalities for employees and contractors.
Fatalities FY 2020 FY 2021 FY 2022 FY 2023
Employees

Please provide supporting evidence
or web link:
Contractors

Please provide supporting evidence
or web link
Data Consistency
□ We report publicly on this information, but the data in the table above differs from our publicly reported figures. Please
provide an explanation in the comment box for this difference: _____________
Question-Specific Guidance & Definitions Additional credit will be granted for relevant publicly available
Work-related fatalities: The death of a worker arising from
Number of work-related fatalities for employees and
an occupational disease or injury sustained or contracted
contractors for at least the most recent reported year.
while performing work that is controlled by the organization
or that is being performed in workplaces that the organization
Please note: If you have 25 or less FTEs your organization,
controls.
then please mark the question as 'Not applicable'.
Contractor: Persons or organizations working onsite or

offsite on behalf of an organization. A contractor can contract Standards & frameworks
their own workers directly, or contract sub-contractors or
CSRD - S1-14 88b AR 82, AR 89-AR 91
independent contractors.
EDCI - Number of work related fatalities
ESG Disclosure Standards (China) - S.1.3.3 Response to
Data Requirements safety accidents and work-related injuries
GISD - Health and safety (%)
GRI Disclosure - 2-5, 403-10, 403-9
IRIS+ - OI6525
228 / 252
SASB - EM-CO-320a.1, EM-EP-320a.1, EM-IS-320a.1, EM- SFDR Principal Adverse Impacts - Social and employee
MD-540a.1, EM-MM-320a.1, EM-RM-320a.1, EM-SV-320a.1, matters
FB-AG-320a.1, FB-MP-320a.1, IF-EN-320a.1, IF-EU-320a.1, UNGP - C5.1
IF-HB-320a.1, IF-WM-320a.1, RR-FC-320a.1, RR-WT-320a.1, WEF Metrics - Employee well-being (%), Health and safety
RT-CH-320a.1, RT-IG-320a.1, TR-AF-320a.1, TR-MT-540a.1, (%)
TR-RO-320a.1
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Lost-Time Injury Frequency Rate (LTIFR) Employees
Assessment Focus
Question Rationale
Poor occupational health and safety (OHS) performance has a contingent liabilities. We expect companies to keep track of
direct negative impact on labor costs through lower the lost time injuries of their employees and to prevent
productivity. Lower performance not only poses a threat to a exacerbation of the injuries.
increased operating costs in the form of fines and other
Question Layout
Does the company publicly report on lost-time injury frequency rate for employees (per one million hours worked)? For each row in the
or one or
more fiscal years, this data will only be accepted if evidence of third-party verification is provided.
If the company only tracks LTIFR on a consolidated basis, without distinguishing between employees and contractors, please use this
question to report the consolidated number.
o Yes, the company publicly reports on lost-time injury frequency rate for employees. Please indicate where this information
is available in public reporting or corporate website.
LTIFR Unit FY 2020 FY 2021 FY 2022 FY 2023
Employees LTIFR (n/million hours
worked)
Dropdown:
• LTIFR LTIR (n/200,000 hours
• LTIR worked)
Data coverage (as % of employees, percentage of:
operations or revenues)
Dropdown:
• Employees
• Operations
• Revenues
□ Our data has been third-party verified in the most recent financial year reported and is available publicly.
Data Consistency
□ The company publicly reports on this information, but the data in the table above differs from our publicly reported
figures. Please provide an explanation in the comment box for this difference: _____________
□ The company has a temporary coverage reduction or target challenge due to corporate actions. Please briefly explain if
a merger, acquisition, divestment, etc. has temporarily caused a reduction in your ability to report optimal coverage or
caused your target to appear abnormal: _____________
□ The company only track lost-time injury frequency rate (LTIFR) on a consolidated basis.
Please provide the combined figures in the table above and mark "Not Applicable" in the next question (Lost-Time
Injuries Frequency Rate (LTIFR) - Contractors).
Alternative Metric
□ Please provide your company's Lost Workday Rate (LWR) or Days Away/Restricted or Transfer Rate (DART) for
employees (per 200,000 hours worked). For each row in the table, it is mandatory that the values provided are in
th
data will only be accepted if evidence of third-party verification is provided.
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Alternative Metric Unit FY 2020 FY 2021 FY 2022 FY 2023
Employees n/200,000 hours worked
Dropdown:
• Lost Workday Rate
• Days Away Restricted
Transfer Rate
Data coverage (as % of employees, percentage of:
Dropdown:
• Employees
• Operations
• Revenues
□ The data has been third-party verified in the most recent financial year reported. Please provide supporting evidence.
Data Consistency
□ The company publicly reports on this information, but the data in the table above differs from our publicly reported
figures. Please provide an explanation in the comment box for this difference: _____________
□ The company has a temporary coverage reduction or target challenge due to corporate actions. Please briefly explain if
a merger, acquisition, divestment, etc. has temporarily caused a reduction in your ability to report optimal coverage or
□ The company only tracks DART or LWR on a consolidated basis.
□ Please provide the combined figures in the table above and mark "Not Applicable" in the next question (Lost-Time
Injuries Frequency Rate (LTIFR) - Contractors).
Question-Specific Guidance & Definitions that resulted in days away from work, restricted work activity
and/or job transfer that a company has experienced in a fiscal
Lost-time injuries frequency rate (LTIFR): Any work-related year.
injury that results in the company employee or third-party
contractor employee not being able to return to work the next Dart rate formula: total number of DART incidents x 200,000/
scheduled work day/shift. number of employee labour hours worked in the fiscal year.
The LTIFR is the number of lost-time injuries per million hours LOST WORKDAY RATE (LWD): A mathematical calculation that
worked, calculated using the formula: describes the number of lost workdays per 100 full-time
employees in last fiscal year.
LTIFR=(Number of lost-time injuries ) / (Total hours worked in
accounting period)x 1'000'000 LWD Rate formula: Total Number of Lost Days x 200,000 /
Number of Employee Labor Hours Worked
Lost- Time Injury Rate (LTIR)
Any work-related injury that results in the company employee A Lost Workday Incident takes into account the number of
or third-party contractor employee not being able to return to days of missed work, not days that involved restricted tasks.
work the next scheduled workday/shift. The day the illness or injury occurred is not counted as a lost
workday, and the total number possible for lost days due to a
The LTIR is the number of lost-time injuries per 200,000 hours single incident is capped at 180.
worked, calculated using the formula:
Data Requirements
LTIR=(Number of lost-time injuries ) / (Total hours worked in If your company combines LTIFR for employees and
accounting period)x 200'000 contractors, then please answer this question combining the
two figures and mark the question "Lost-Time Injuries
DART (Days Away/Restricted or Transfer Rate): A Frequency Rate (LTIFR) - Contractors" as "Not Applicable".
mathematical calculation that describes the number of
recordable injuries and illnesses per 100 full-time employees
231 / 252
Disclosure requirements for public question: Publicly
available evidence covering the following aspect of this Please note that we only expect your company to report ONE
question must be included: metric only. If your company reports both LTIFR and one of
• Employee Lost-Time Injury Frequency Rate (LTIFR) the alternative metrics, please use the LTIFR as this is the
for at least the most recent reported year OR preferred metric.
• Employee Days Away/Restricted or Transfer Rate
(DART) for least the most recent reported year OR If your company reports one metric for employees and
• Employee Lost Workday Rate (LWD) for least the another for contractors, this is acceptable.
most recent reported year.
Please note that Lost Time Injury Rate (200,000 hours) can be
Please note: if Lost-Time Injury Frequency Rate (LTIFR) is only selected in the Standard Metric table as the figure can be
tracked a consolidated basis (employees and contractors multiplied by 5 to reach the calculation of LTIFR (1 million).
combined) the combined rate for at least the most recent
reported year should be provided. Standards & frameworks
CSRD - S1-14 88e
Please note:
EDCI - Number of work related injuries
• If you have 25 or less FTEs in your organization,
ESG Disclosure Standards (China) - S.1.3.3 Response to
then please mark the question as Not
safety accidents and work-related injuries
Applicable .
GISD - Frequency of occupational injuries, Health and safety
• If you have 26-100 FTEs, then also this
(%), Incident rate of occupational injuries
Not Applicable .
Data Consistency IRIS+ - OI3757, OI7060
If the occupational health & safety performance data SASB - EM-MM-320a.1, SV-LF-320a.1, TR-CL-320a.1, TR-MT-
reported in the questionnaire do not correspond to the 320a.1
publicly reported figures, the corresponding option should be SFDR Principal Adverse Impacts - Social and employee
marked and the discrepancy should be explained. This option matters
should not be indicated if the information is not publicly UNGC Questionnaire - L9
reported at all. UNGP - C5.1
232 / 252
Lost-Time Injury Frequency Rate (LTIFR) Contractors
Assessment Focus
Question Rationale
Poor occupational health and safety (OHS) performance has a contingent liabilities. We expect companies to keep a track of
direct negative impact on labor costs through lower the lost time injuries of their contractors to restrict the
productivity. Lower performance not only poses a threat to occurrence of such events and ensure overall safety across
the supply chain.
increased operating costs in the form of fines and other
Question Layout
Please provide your company's lost-time injury frequency rate for contractors (per one million hours worked). For each row in the
table, it is mandatory that the values provided are in the same unit. If your compan
more fiscal years, this data will only be accepted if evidence of third-party verification is provided.
If you only track LTIFR on a consolidated basis, without distinguishing between employees and contractors, please mark this question
as "Not applicable" and use the LTIFR - Employees question to report the consolidated number.
LTIFR Unit FY 2020 FY 2021 FY 2022 FY 2023

Contractors LTIFR (n/million hours
worked)
Dropdown: LTIR (n/200,000 hours
• LTIFR worked)
• LTIR
Data coverage (as % of contractors, percentage of:
Dropdown:
• Contractors
• Operations
• Revenues
Public Reporting
Data Consistency
233 / 252
□ We have a temporary coverage reduction or target challenge due to corporate actions. Please briefly explain if a
merger, acquisition, divestment, etc. has temporarily caused a reduction in your ability to report optimal coverage or
Alternative Metric
Please provide your company's Lost Workday Rate (LWR) or Days Away/Restricted or Transfer Rate (DART) for contractors (per
200,000 hours worked). For each row in the table, it is mandatory that the values provided are in the same unit. If your comp
or DART for contractors is equal to zero for one or more fiscal years, this data will only be accepted if evidence of third-party
verification is provided.
Alternative Metric Unit FY 2020 FY 2021 FY 2022 FY 2023

Contractors n/200,000 hours worked
Dropdown:
• Lost Workday Rate
• Days Away Restricted
Transfer Rate
Data coverage (as % of contractors, percentage of:
Dropdown:
• Contractors
• Operations
• Revenues
Public Reporting
Data Consistency
target to appear abnormal: _____________
Question-Specific Guidance & Definitions Lost- Time Injury Rate (LTIR)

Any work-related injury that results in the company employee
Lost-time injuries frequency rate (LTIFR): A lost-time injury is
or third-party contractor employee not being able to return to
defined as any work-related injury that results in the
work the next scheduled workday/shift.
company employee or third-party contractor employee not
being able to return to work the next scheduled work
The LTIR is the number of lost-time injuries per 200,000 hours
day/shift.
LTIFR ONLY counts the lost time on the company's premises

LTIR=(Number of lost-time injuries ) / (Total hours worked in
for contractors.
accounting period) x 200'000
The LTIFR is the number of lost-time injuries per million hours

DART (Days Away/Restricted or Transfer Rate): A
mathematical calculation that describes the number of
recordable injuries and illnesses per 100 full-time employees
LTIFR=(Number of lost-time injuries ) / (Total hours worked in
that resulted in days away from work, restricted work activity
accounting period) x 1'000'000
234 / 252
and/or job transfer that a company has experienced in a fiscal • Contractor Days Away/Restricted or Transfer Rate
year. (DART) for least the most recent reported year OR
• Contractor Lost Workday Rate (LWD) for least the
Dart rate formula: total number of DART incidents x 200,000 / most recent reported year.
number of employee labour hours worked in the fiscal year.
Please note:
LOST WORKDAY RATE (LWD): A mathematical calculation that • If you have 25 or less FTEs in your organization,
describes the number of lost workdays per 100 full-time then please mark the question as Not
employees in last fiscal year. Applicable .
• If you have 26-100 FTEs, then also this
LWD Rate formula: Total Number of Lost Days x 200,000 / Not Applicable .
Number of Employee Labor Hours Worked
Data Consistency
A Lost Workday Incident takes into account the number of
days of missed work, not days that involved restricted tasks. If the occupational health & safety performance data
The day the illness or injury occurred is not counted as a lost reported in the questionnaire do not correspond to the
workday, and the total number possible for lost days due to a publicly reported figures, the corresponding option should be
single incident is capped at 180. marked and the discrepancy should be explained. This option
should not be indicated if the information is not publicly
Contractor: Persons or organizations working onsite or offsite reported at all.
on behalf of and organization. A contractor can contract their
own workers directly, or contract sub-contractors or Please note that we only expect your company to report ONE
independent contractors. metric only. If your company reports both LTIFR and one of
the alternative metrics, please use the LTIFR as this is the
preferred metric.
Data Requirements
If your company reports one metric for employees and
If your company combines LTIFR for employees and
another for contractors, this is acceptable.
contractors, then please answer "Lost-Time Injuries
Frequency Rate (LTIFR) - Employees" combining the two
Please note that Lost Time Injury Rate (200,000 hours) can be
figures, mark "Lost-Time Injuries Frequency Rate (LTIFR) -
selected in the Standard Metric table as the figure can be
Contractors" as "Not Applicable" and explain in the
multiplied by 5 to reach the calculation of LTIFR (1 million).
comment box.
Disclosure requirements for partially public question. Standards & frameworks

Additional credit will be granted for relevant publicly available CSRD - S1-14 88e AR 89-AR 91, AR 95, S1-14 89
evidence covering the following aspect of this question: EDCI - Number of work related injuries
• Contractor Lost-Time Injury Frequency Rate (LTIFR) GRI Disclosure - 2-5, 403-9
for at least the most recent reported year. SASB - TR-MT-320a.1
235 / 252
Privacy Protection
Networked data and globalised corporate activities require reputational risk, and exclusion from certain activities, a
careful handling. Insufficient database and network company-wide privacy policy is paramount. Our questions
protection, unclear management of personal information and focus on the coverage of the company's privacy policy and the
vague database access rules could expose companies to large mechanism in place to ensure the policy's effective
risks in case of personal data leakage and misuse, or implementation.
unauthorized access. For companies to avoid legal costs,
Privacy Policy: Systems/ Procedures
Assessment Focus
Question Rationale
Networked data and globalized corporate activities require comprehensive privacy policy spanning across their
diligent information handling. In order to avoid the risks businesses, along with a sound implementation framework.
associated with these developments such as legal costs, This question assesses whether the company has the
reputational damage, and the exclusion from certain requisite mechanisms in place to ensure that its privacy
activities companies must endeavor to implement a policy is effectively implemented.
Question Layout
Does the company have measures in place to ensure effective implementation of its privacy policy and is it available publicly?
□ Yes, the company has measures in place to ensure effective implementation of its privacy policy. Please indicate where this
Aspect Please provide supporting evidence for the aspect and indicate page numbers:
□ Privacy policy applies to the entire

operations, including suppliers
□ Designated person or department

responsible for privacy issues
□ Privacy policy system embedded in group-

wide risk/compliance management
□ Disciplinary actions in case of breach (i.e.,

zero tolerance policy)
□ We conduct third-party audits of the privacy

policy compliance.
□ We conduct internal audits of privacy policy

compliance.
236 / 252
Question-Specific Guidance & Definitions Data Requirements
Privacy Policy: An internal statement that governs an Disclosure requirements for public question: This question
It is requires supporting evidence from the public domain. The
directed at those members of the organization who might information provided must be included in your public
handle or make decisions regarding personal information, reporting (e.g., annual report, sustainability report, integrated
instructing them on the collection, use, storage, and report, company publications, separate fuel efficiency
destruction of the data, as well as any specific rights the data strategy document) or corporate website. Any response that
subjects may have. It may also be referred to as a data cannot be verified in the attached public document(s) will not
protection policy. This policy is different from the privacy be accepted.
notice, which refers to an external statement to
consumers/customers to describe how the company collects, Privacy policy applies to the entire operations, including
uses, retains, and discloses personal information. This suppliers:
question specifically focuses on the internal statement all operations. The same policy/standards should be
directed at the members of the company handling private applicable to suppliers. A mention of privacy protection or
information. confidentiality of information in the Codes of Conduct is not
sufficient, we expect a separate privacy policy or section on
Data protection is about protecting any information relating privacy protection.
to an identified or identifiable natural (living) person,
including names, dates of birth, photographs, video footage, Defined point of contact in place for escalation of privacy
email addresses, and telephone numbers. Other information issues: We expect companies to have a designated person or
such as IP addresses and communications content - related department that employees can reach out to in case of any
to or provided by end-users of communications services - are privacy issues or concerns. If this person/department is not
also considered personal data. (Source: European Data dedicated to privacy policy issues but to a general escalation
Protection Supervisor) of concerns, there should be clear evidence that privacy
policy issues should be conducted through this channel as
Personal data is any information that relates to an identified well.
or identifiable living individual. Different pieces of
information, which are collected together can lead to the Privacy policy system embedded in group-wide
identification of a particular person, and also constitute risk/compliance management: Privacy policy systems and
personal data: (Source: European Data Protection Supervisor) procedures should be embedded in group-wide
risk/compliance management. Privacy protection should be
Examples of personal data include included in the overall operational risk/compliance
• a name and surname; management structures of the company.
• a home address;
• an email address such as Disciplinary actions in case of breach: We expect the policy to
name.surname@company.com; cover the corrective and disciplinary actions taken in case of
• an identification card number; a breach of the policy. A general mention of disciplinary
• location data (for example the location data actions in the Codes of Conduct is not sufficient, we expect
function on a mobile phone)*; the statement to be specific to data privacy.
• an Internet Protocol (IP) address;
• the advertising identifier of your phone; Audit of privacy policy compliance: Please specify whether
• data held by a hospital or doctor, which could be a you conduct internal and/or external audits of your privacy
symbol that uniquely identifies a person policy compliance. If your company conducts both, please
tick both options. Full points will be granted if the company
Personally identifiable information (PII) is any information provides evidence that it conducts external audits (in that
that relates to an identified or identifiable living individual. It case, internal audits are not required).
is another term for Personal data. (Source: NIST Computer
Security Resource Center) Supporting evidence:
Suppliers (or service providers) are understood as any third public domain. The information provided has to be
party that provides goods or services to the company (such as included in your public reporting (e.g. annual report,
a consultant, contractor, advisor, or vendor). sustainability report, integrated report, company
publications, separate fuel efficiency strategy
document) or corporate website.
237 / 252
• Any response that cannot be verified in the attached Professional & Commercial Services, SASB Code: SV-PS-
public document(s) will not be accepted. 230a.2 is relevant for this question.
E-Commerce, SASB Code: CG-EC-220a.1 is relevant for this
question.
References:
Consumer Finance, SASB Code: FN-CF-220a.1 is partially
SASB: SASB Data Privacy Accou relevant for this question.
Advertising and Marketing, SASB Code: SV-AD-220a.1 is
are relevant to this question. relevant for this question.
Software & IT Services, SASB Code: TC-SI-220a.1 is relevant
for this question. Standards & Frameworks
Telecommunication Services, SASB Code: TC-TL-220a.1 is
relevant for this question. CSRD - ESRS 2 MDR-P 65a
Internet Media & Services, SASB Code: TC-IM-220a.1 is IRIS+ - OI5102
relevant for this question.
238 / 252
Customer Privacy Information
Assessment Focus
Question Rationale
Networked data and globalized corporate activities require comprehensive privacy policy spanning across their
diligent information handling. In order to avoid the risks businesses, along with a sound implementation framework.
associated with these developments such as legal costs, For this question, we as
reputational damage, and the exclusion from certain customers on privacy protection issues.
activities companies must endeavour to implement a
Question Layout
Does the company inform customers regarding privacy protection issues and is this information available publicly?
□ Yes, the company informs its customers regarding privacy protection issues. Please indicate where this information is
□ Nature of information captured
□ Use of the collected information
□ Possibility for customers to decide how private data is collected, used, retained and processed
□ Opt-out option is available
□ Opt-in consent is required
□ Request access to data held by the company
□ Request their data to be transferred to other service providers
□ Request their data to be corrected
□ Request their data to be deleted
□ How long the information is kept on corporate files
□ How the information is protected
□ Third-party disclosure policy (private and public entities)
□ We monitor the percentage of users whose customer data is used for secondary purposes. Please indicate the
percentage of customers whose data is used for secondary purposes and provide publicly available evidence.
Question-Specific Guidance & Definitions service offerings, and transferring data or information to a
third party through sale, rental, or sharing.
Customer: Someone who buys services or goods from
someone else. In the context of this questionnaire, we focus
on customers for B2B companies. Data Requirements
Consumer: Someone that consumes a certain product or
commodity. In the field of economics, a consumer can either
be a single person or an entire organization using a certain
public reporting (e.g. annual report, sustainability report,
type of service. In the context of this questionnaire, we focus
integrated report, company publications, separate fuel
on consumers for B2C companies.
efficiency strategy document) or corporate website.
Secondary purpose: Data collection for a secondary purpose

is defined as the intentional use of data by a company that is
outside the primary purpose for which the data was collected.
Examples of secondary purposes include, but are not limited
to, selling targeted
239 / 252
Internet Media & Services: https://www.sasb.org/wp-
References content/uploads/2018/11/Internet_Media_Services_Standar
d_2018.pdf, Page 6
SASB Code: TC-IM-220a.1 is relevant to this question.
policies and practices relating to collection, usage, and Professional & Commercial Services:
retention of customer information and personally identifiable https://www.sasb.org/wp-
content/uploads/2018/11/Professional_Commercial_Service
Software & IT Services: https://www.sasb.org/wp- s_Standard_2018.pdf, Page 6
content/uploads/2018/11/Software_IT_Services_Standard_2 SASB Code: SV-PS-230a.2 is relevant to this question.
018.pdf, Page 6
SASB Code: TC-SI-220a.1 is relevant to this question.
Telecommunication Services: https://www.sasb.org/wp-
content/uploads/2018/11/Telecommunication_Services_Stan IRIS+ - OI4753
dard_2018.pdf, Page 6 SASB - CG-EC-220a.2, FN-CF-220a.1, HC-DY-230a.2, HC-MC-
SASB Code: TC-TL-220a.1 is relevant to this question. 230a.1, SV-AD-220a.1, SV-ED-230a.2, TC-IM-220a.1, TC-IM-
220a.2, TC-SI-220a.1, TC-TL-220a.1, TC-TL-220a.2
240 / 252
06
GRI Mapping Index
The table below maps the Corporate Sustainability disclosure. We have produced this table in order to provide
Assessment (CSA) questions with GRI Standards. GRI topic participants with an extensive overview to help minimize the
disclosure codes are shown when there is at least one effort of filling in the CSA, but cannot guarantee the
datapoint shared between the CSA question and the GRI topic completeness of the mapping.
basis for structured reporting on widely accepted
Please note that reporting according to GRI Standards is not sustainability topics, many of which are also addressed in the
a prerequisite for completing the CSA, but rather serves as a CSA.
GRI Mapping - Economic Dimension
Criterion Question GRI Standards

Business Ethics Controversial Weapons
Business Ethics Codes of Conduct 11.20
Business Ethics Crime Prevention: Business Policy/ Procedures
Business Ethics Corruption & Bribery
Business Ethics Codes of Conduct: Systems/ Procedures 2-26
2-27
205-3
406-1
Business Ethics Reporting on breaches 418-1
Business Ethics UN Global Compact Membership
Corporate Governance Board Type 2-9
Corporate Governance Board Independence 2-10
Corporate Governance Non-Executive Chairperson/ Lead Director 2-11
Corporate Governance Board Diversity Policy 2-10
2-9
Corporate Governance Board Gender Diversity 405-1
2-9
2-10
Corporate Governance Board Effectiveness 2-18
Corporate Governance Board Average Tenure 2-9
Corporate Governance Board Industry Experience 2-9
Corporate Governance CEO Compensation - Success Metrics 2-19
Corporate Governance CEO Compensation - Long-Term Performance Alignment 2-19
Corporate Governance Management Ownership
Corporate Governance Management Ownership Requirements
2-15
Corporate Governance Government Ownership 201-4
Corporate Governance Family Ownership 2-15
Corporate Governance CEO-to-Employee Pay Ratio 2-21
Information Security/ Cybersecurity & System
Availability IT Security/ Cybersecurity Governance
Availability IT Security/ Cybersecurity Measures
Availability IT Security/ Cybersecurity Process & Infrastructure
Innovation Management Product Innovations (Healthcare)
Innovation Management Healthcare Clinical Pipeline
Innovation Management Tobacco Alternatives & Reduced-Risk Products
Market Opportunities New Business Opportunities (Electricity & Multi-Utilities)
241 / 252
Market Opportunities New Business Opportunities (Gas)
Market Opportunities New Business Opportunities (Water)
Market Opportunities Current Investment Budget (Electricity & Multi-Utilities)
Market Opportunities Current Investment Budget (Gas)
Market Opportunities Current Investment Budget (Water)
Market Opportunities Revenues from New Business Opportunities
Market Opportunities Smart Meter Penetration
2-14
Materiality Materiality Analysis 3-1
Materiality Material Issues for Enterprise Value Creation 3-2
Materiality Materiality Metrics for Enterprise Value Creation 3-3
Materiality Material Issues for External Stakeholders
Materiality Materiality Metrics for External Stakeholders
Policy Influence Lobbying and Trade Associations - Climate Alignment
11.22
12.22
Policy Influence Largest Contributions & Expenditures 2-28
11.22
12.22
14.24
Policy Influence Contributions & Other Spending 415-1
Product Quality & Recall Management Warranty Provisions
Product Quality & Recall Management Product Recalls
Product Quality & Recall Management Product Recalls (Health Care)
Product Quality & Recall Management Product Recalls (Automobiles & Auto Components)
Product Quality & Recall Management Compliance to Regulatory Standards
Risk & Crisis Management Risk Management
Risk & Crisis Management Risk Management Processes
Risk & Crisis Management Risk Governance
Risk & Crisis Management Export Control Regime Compliance Systems
Risk & Crisis Management Export Control Regime Compliance Metrics
Risk & Crisis Management Global Systemically Important Banks
Risk & Crisis Management Emerging Risks
Supply Chain Management Supplier Code of Conduct 403-1
308-1
Supply Chain Management Supplier Screening 414-1
308-2
Supply Chain Management Supplier Assessment and Development 414-2
2-5
Supply Chain Management KPIs for Supplier Screening 2-6
2-5
308-2
Supply Chain Management KPIs for Supplier Assessment and Development 414-2
Supply Chain Management Supplier ESG Programs
Supply Chain Management Conflict Minerals
Sustainable Finance Sector Activities
Sustainable Finance Sustainable Investing Policy
Sustainable Finance Sustainable Stewardship
Sustainable Finance Sustainable Financing Policy
Sustainable Finance Sustainable Project Finance Policy
Sustainable Finance Sustainable Advisory Policy
Sustainable Finance Sustainable Insurance Underwriting Policy
Sustainable Finance Sustainable Exchange Programs
Sustainable Finance Sustainable Investing Products & Services
Sustainable Finance Sustainable Financing Products & Services
Sustainable Finance Sustainable Advisory Products & Services
242 / 252
Sustainable Finance Sustainable Insurance Underwriting Products & Services
Sustainable Finance ESG Products & Services for Data Providers
Sustainable Finance Sustainable Indices
Tax Strategy Tax Strategy and Governance 207-1
2-1
Tax Strategy Tax Reporting 207-4
Tax Strategy Effective Tax Rate
Transparency & Reporting Sustainability Reporting Boundaries 2-2
Transparency & Reporting Sustainability Taxonomies
Transparency & Reporting Sustainability Reporting Assurance 2-5
243 / 252
GRI Mapping - Environmental Dimension
Biodiversity Biodiversity Risk Assessment
Biodiversity Biodiversity Commitment 101-1
Biodiversity No Deforestation Commitment

101-2
101-5
Biodiversity Biodiversity Exposure & Assessment 14.4
Biodiversity Biodiversity Mitigating Actions 101-2

2-5
Climate Strategy Direct Greenhouse Gas Emissions (Scope 1) 305-1
2-5
Climate Strategy Indirect Greenhouse Gas Emissions (Scope 2) 305-2
2-5
Climate Strategy Indirect Greenhouse Gas Emissions (Scope 3) 305-3
Climate Strategy Methane Emissions 11.1
Climate Strategy Perfluorocarbons Emissions
Climate Strategy SF6 Emissions

11.2
Climate Strategy Climate Governance 12.2
Climate Strategy TCFD Disclosure

11.2
Climate Strategy Climate-Related Management Incentives 12.2
Climate Strategy Climate Risk Management
Climate Strategy Financial Risks of Climate Change 201-2
Climate Strategy Financial Opportunities Arising from Climate Change
Climate Strategy Climate-Related Scenario Analysis
Climate Strategy Physical Climate Risk Adaptation 14.2

11.2
12.2
Climate Strategy Emissions Reduction Targets 305-5
Climate Strategy Low-Carbon Products
Climate Strategy Internal Carbon Pricing
Climate Strategy Net-Zero Commitment
Decarbonization Strategy Net-Zero Targets for Financed Emissions
Decarbonization Strategy Scope 3 Financed Absolute Emissions
Decarbonization Strategy Scope 3 Financed Emission Intensity
Decarbonization Strategy Coal Financing Policy
Decarbonization Strategy Coal Investment Policy
Decarbonization Strategy Coal Re/Insurance Underwriting Policy
Decarbonization Strategy Unconventional Oil & Gas Financing Policy
Decarbonization Strategy Unconventional Oil & Gas Investment Policy

Unconventional Oil & Gas Re/Insurance Underwriting
Decarbonization Strategy Policy
Energy Energy Management Programs

2-5
Energy Energy Consumption 302-1
Energy Energy Intensity
Energy Data Center Efficiency
Energy Share of Renewable Energy in Data Centers
244 / 252
Energy Renewable Energy Consumption
Environmental Policy & Management Systems Environmental Policy
Environmental Policy & Management Systems Coverage of Environmental Management Policy

Scope of Corporate Environmental Requirements/
Environmental Policy & Management Systems Guidelines
Environmental Policy & Management Systems Verification of Environmental Programs
Environmental Policy & Management Systems Return on Environmental Investments
Environmental Policy & Management Systems Environmental Violations 2-27
Environmental Policy & Management Systems Public availability of EIA/ SIA Results
Packaging Packaging Commitment

301-1
Packaging Packaging Material 301-3
Packaging Plastic Packaging
2-5
Waste & Pollutants NOx Emissions 305-7
Waste & Pollutants Waste Management Programs

2-5
Waste & Pollutants SOx Emissions 305-7
2-5
306-4
Waste & Pollutants Waste Disposal 306-5
Waste & Pollutants Direct Mercury Emissions

2-5
306-4
Waste & Pollutants Hazardous Waste 306-5
Waste & Pollutants Dust Emissions

12-6
Waste & Pollutants Mineral Waste 14.5
Waste & Pollutants Ash & Gypsum Waste

2-5
Waste & Pollutants Volatile Organic Compounds Emissions 305-7
Waste & Pollutants Construction Waste Management
Waste & Pollutants Specific NOx Emissions for Passenger Transport
Waste & Pollutants Specific NOx Emissions for Cargo Transport

12.13
Waste & Pollutants Tailings Commitment 14.6
Waste & Pollutants Chemical Oxygen Demand

12.13
Waste & Pollutants Tailings Management 14.15
Waste & Pollutants Absorbable Organic Halogens
Waste & Pollutants Tailings Risks Potential 14.6
Waste & Pollutants Acid Rock Drainage Management
Waste & Pollutants Hydrocarbon Spills
Waste & Pollutants Food Loss & Waste Commitment

13-9
Waste & Pollutants Food Loss & Waste Impact 2-5
Product Stewardship Product Design Criteria
Product Stewardship Life Cycle Assessment
Product Stewardship Resource Efficiency Benefits of Products
245 / 252
Product Stewardship Renewable Raw Materials
Product Stewardship Use of Recycled & Sustainably Sourced Materials
Product Stewardship Exposure to Hazardous Substances
Product Stewardship Hazardous Substances Commitment
Product Stewardship End of Life Cycle Responsibility
Product Stewardship Environmental Labels & Declarations
Product Stewardship Specific Fuel Consumption for Passenger Transport
Product Stewardship Specific Fuel Consumption for Cargo Transport
Product Stewardship Circular Fashion Commitment
Product Stewardship Circular Fashion Programs
Product Stewardship Circular Fashion Indicators
Product Stewardship On-Site Energy Generation
Product Stewardship Building Certification & Benchmarking
Product Stewardship Energy Ratings & Benchmarking
Product Stewardship Energy Efficiency Programs for Real Estate Portfolio
Product Stewardship Share of Low-Energy Buildings

Energy Efficiency Approach for New Buildings -
Product Stewardship Construction
Product Stewardship Electricity Transmission & Distribution Losses
Product Stewardship Electricity Transmission & Distribution Losses
Product Stewardship Electricity Transmission & Distribution Reliability
Product Stewardship Gas Leakage Rate
Product Stewardship Attributes of Building Materials
Product Stewardship Revenues from Sustainable Construction
Product Stewardship Electricity Generation Mix
Product Stewardship Electricity Capacity Mix
Product Stewardship Efficiency of Generation
Product Stewardship Availability Factor of Plants
Product Stewardship Oil & Gas Production
Product Stewardship Oil & Gas Reserves
Product Stewardship Finding & Development Costs & Production Costs
Product Stewardship LNG Capacity
Product Stewardship Renewable Energy Production
Product Stewardship Fleet Exposure
Product Stewardship Fleet GHG Intensity
Product Stewardship Maritime Fleet Decarbonization
Product Stewardship Rail Fleet Decarbonization
Product Stewardship Road Fleet Decarbonization
Product Stewardship Air Fleet Decarbonization
Product Stewardship Fleet Age
Product Stewardship Measures for Improving Fuel Efficiency
Product Stewardship Airline Industry Engagement
Product Stewardship Electric Vehicle (EV) Battery Degradation
246 / 252
Product Stewardship Electric Vehicle Efficiency
Product Stewardship Governance Checks for Vehicle Efficiency & Emissions
Product Stewardship Vehicle Fuel & Carbon Efficiency
Product Stewardship Alternative Drive Trains
Product Stewardship Co-Processing Rate
Sustainable Raw Materials Sustainable Agricultural Commitment
Sustainable Raw Materials Certifications of Agricultural Crops
Sustainable Raw Materials Certifications of Animal Products
Sustainable Raw Materials Animal Welfare Policy
Sustainable Raw Materials Animal Welfare Disclosure 13.11
Sustainable Raw Materials Share of Organic Products
Sustainable Raw Materials Raw Materials Policy
Sustainable Raw Materials Raw Materials Programs
Sustainable Raw Materials Plant & Animal-Derived Textile Materials

301-1
Sustainable Raw Materials Plastic Raw Materials 301-2
301-2
301-3
301-4
301-5
301-6
301-7
Sustainable Raw Materials Metal Raw Materials 301-8
Sustainable Raw Materials Certified Wood
Sustainable Raw Materials Recycled Building Materials
Sustainable Forestry Practices Chain of Custody Certification
Sustainable Forestry Practices Forest Management Certification
Sustainable Forestry Practices Small Forests Owners
Water Water Efficiency Management Programs
Water Water Consumption 303-4

2-5
303-3
303-4
Water Water Consumption in Water-Stressed Areas 303-5
Water Ultra-Pure Water Usage
Water Water-Saving Devices
Water Water Efficiency Programs for Real Estate Portfolio
Water Leakage Rate
Water Business Impacts of Water Related Incidents
Water Exposure to Water Stressed Areas
247 / 252
Water Water Risk Management Programs
Water Exposure of Suppliers to Water Risks
Water Water Risks Management of Suppliers
248 / 252
GRI Mapping - Social Dimension
GRI
Criterion Question Standards
Contribution to Societal Healthcare Access to Healthcare Programs (Products & Drugs)
Contribution to Societal Healthcare Access to Healthcare Programs (Products)
Contribution to Societal Healthcare Access to Healthcare Programs
Contribution to Societal Healthcare Local Capacity Building
Contribution to Societal Healthcare Patent Filing Policy
Contribution to Societal Healthcare Impact on Access to Healthcare
Contribution to Societal Healthcare Partnerships for Access to Healthcare
Contribution to Societal Healthcare Fair Pricing
Contribution to Societal Healthcare Contribution to Increasing Healthcare Efficiency
Contribution to Societal Healthcare Measure Contribution to Health Outcome
Contribution to Societal Healthcare Accessibility & Transparency of Outcome Data
Contribution to Societal Healthcare HTA Support of Value Proposition
Community Relations Resource Transformation

12-3
Community Relations Mine Closure 14.8
Community Relations Active Community Engagement 413-1

11.15
12.9
14.1,
Community Relations Community Consultation Framework & Implementation 413-1
Community Relations Relocation Programs 11.6

11.7
12.11
Community Relations Indigenous Peoples & Culture Preservation 14.11
11.18
Community Relations Security Forces 12.12
14.9
Community Relations Local Employment 202-2
Community Relations Artisanal Small-scale Mining 14.13
Community Relations Social Integration in New Buildings & Reconstruction

11.15
12.9
Community Relations Stakeholder Engagement Policy 14.10
Community Relations Stakeholder Engagement Programs
Community Relations Social Integration Initiatives
Customer Relations Tenant Health & Wellbeing Programs
Customer Relations Tenant Health & Wellbeing Measures
Customer Relations Online Strategies & Customers Online
Customer Relations Customer Satisfaction Measurement
Customer Relations Sales Channels Variety & Innovation
Customer Relations Sales Effectiveness Targets
Customer Relations Quality Management & Audits of Distribution Networks
Customer Relations Incentives for Distribution Networks
Customer Relations Ethical Marketing & Advertising
Customer Relations Brand Management Metrics
Customer Relations Ethical Marketing Commitment
Customer Relations Ethical Marketing Complaints Tracking
Customer Relations Direct-to-Consumer Marketing
249 / 252
GRI
Customer Relations Code of Ethics for Advertising
Customer Relations Content Moderation Policy
Customer Relations Editorial Policy
Customer Relations Protection of Children
Financial Inclusion Financial Inclusion Commitment
Financial Inclusion Financial Inclusion Product & Services
Financial Inclusion Financial Inclusion - Non-Financial Support
Health & Nutrition Marketing Self-Regulation on Health & Nutrition
Health & Nutrition Health & Nutrition Reformulation
Health & Nutrition Development of Health & Nutrition Strategy
Human Capital Management Training & Development Inputs 404-1
Human Capital Management Employee Development Programs
Human Capital Management Hiring 401-1
Human Capital Management Type of Performance Appraisal 404-3
Human Capital Management Long-Term Incentives for Employees
Human Capital Management Employee Support Programs 401-2
Human Capital Management Employee Turnover Rate 401-1
Human Capital Management Trend of Employee Wellbeing
Human Capital Management Human Capital Return on Investment 201-1
Human Rights Human Rights Commitment

2-23
407-1
408-1
409-1
Human Rights Human Rights Due Diligence Process 414-2
408-1
Human Rights Human Rights Assessment 414-2
407-1
408-1
409-1
Human Rights Human Rights Mitigation & Remediation 411-1
Labor Practices Living Wage Commitment 13.21
Labor Practices Living Wage Methodology 13.21
Labor Practices Discrimination & Harassment

2-7
Labor Practices Workforce Breakdown: Gender 405-1
Labor Practices Workforce Breakdown: Race/ Ethnicity & Nationality 405-1

2-5
Labor Practices Gender Pay Indicators 405-2
Labor Practices Freedom of Association 2-30

2-23
403-8
403-9
Occupational Health & Safety OHS Policy 403-10
14.15
403-2
403-5
403-9
403-8
Occupational Health & Safety OHS Programs 403-10
Occupational Health & Safety Absentee Rate 2-5

2-5
403-9
Occupational Health & Safety Fatalities 403-10
250 / 252
GRI
2-5
Occupational Health & Safety Lost-Time Injury Frequency Rate (LTIFR) - Employees 403-9
2-5
Occupational Health & Safety Lost-Time Injury Frequency Rate (LTIFR) - Contractors 403-9
2-5
Occupational Health & Safety Total Recordable Injury Frequency Rate (TRIFR) - Employees 416-1
2-5
Occupational Health & Safety Total Recordable Injury Frequency Rate (TRIFR) - Contractors 403-9
Occupational Health & Safety Process Safety Events - Tier 1 11-8
Transportation Safety Safety Management System
Transportation Safety Accident Rate
Transportation Safety Passenger Fatalities
Privacy Protection Privacy policy: Systems/ Procedures
Privacy Protection Customer Privacy Information
Privacy Protection Use of Customer Data
251 / 252
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CSA Handbook 2024

Corporate Sustainability Assessment

Company Information ....................................................................................................................................................9

Economic Dimension ................................................................................................................................................... 10

Environmental Dimension ......................................................................................................................................... 120

GRI Mapping Index.................................................................................................................................................. 241

How should you use this document?

Criterion Weights Answering Questions

Answer Option Explanation

Not applicable. Please

Media & Stakeholder Analysis

Assessment Focus Icons Description of Information Sought

Disclosure/Transparency Disclosure of qualitative/quantitative information

Exposure/Coverage Coverage of measures implemented or data reported

Trend Trend of key indicators in the last three or four years

Performance Performance of key indicators in comparison to our expected threshold

Awareness Awareness of internal and external issues and measures taken

External Verification Third party verification of data or processes

Sustainability Reporting Boundaries

Public: this question requires publicly available information

Public: this question requires publicly available information

Question-Specific Guidance & Definitions Examples include:

Assurance specialists: Include accountants, certification

Recognized international or national standard: refers to

Standards & frameworks

Public: this question requires publicly available information

Activity-Level Breakdown of Mapping

Activity-Level Mapping: A breakdown of individual activities

Flexible: Public information requirements depend on if the company is listed or non-listed.

□ We have a target share of independent directors on the board. Please specify:

independence used (i.e., if it is in line with local or

Flexible: Public information requirements depend on if the company is listed or non-listed.

□ Yes, we publicly report on our board type.

□ One-tier system (companies with a board of directors)

□ Two-tier system (companies with a supervisory board)

Types of Directors: We outline definitions of possible types of

for in the executive and independent categories. They might 21e

Flexible: Public information requirements depend on if the company is listed or non-listed.

necessary checks and balances to avoid potential abuse of

□ Chairperson is non-executive and independent.

Question-Specific Guidance & Definitions in excess of $60,000 during the curr

4. The director must not be (and must not be affiliated

Flexible: Public information requirements depend on if the company is listed or non-listed.

Question Rationale Diversity adds value to the board through differences in

Standards & frameworks

For two-tier board structures, the policy needs to apply to the

Flexible: Public information requirements depend on if the company is listed or non-listed.

□ Number of female directors:

senior executives and employee representatives should not

For two-tier boards: Employee representatives and senior

Flexible: Public information requirements depend on if the company is listed or non-listed.

Question-Specific Guidance & Definitions

Board Performance Assessments: We consider two types of S. Leving, ISSN 1542-9563

assessments: (1) self-assessments

independent assessments Spielmann

meaning that an independent third party evaluates the

Annual election of board members: refers to a procedure

Flexible: Public information requirements depend on if the company is listed or non-listed.

□ Average tenure of board members in years:

If a company is less than 10 years old, the company should