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Session3 Regulation and Disclosure FT24

This document summarizes a session on regulatory developments in sustainability and sustainability reporting. It outlines key pieces of European legislation and frameworks aimed at achieving the objectives of the European Green Deal, including the Corporate Sustainability Due Diligence Directive currently under discussion. The session also provides an overview of established sustainability reporting standards like the Global Reporting Initiative and the UN Global Compact, as well as the German Sustainability Code.

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100% found this document useful (1 vote)
110 views45 pages

Session3 Regulation and Disclosure FT24

This document summarizes a session on regulatory developments in sustainability and sustainability reporting. It outlines key pieces of European legislation and frameworks aimed at achieving the objectives of the European Green Deal, including the Corporate Sustainability Due Diligence Directive currently under discussion. The session also provides an overview of established sustainability reporting standards like the Global Reporting Initiative and the UN Global Compact, as well as the German Sustainability Code.

Uploaded by

PG
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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ETHICS AND CORPORATE SOCIAL RESPONSIBILITY - SESSION 3:

REGULATORY LANDSCAPE AND SUSTAINABILITY DISCLOSURE

DR. MICHAEL VERBÜCHELN – DIRECTOR METHODOLOGY DEVELOPMENT | JANUARY 09, 2024


Overview of sessions and schedule for the course

Group assignment Session 10:


February 02, 2024 Group presentations and Wrap up

Session 9:
Managing Sustainable Business Models
sustainability
January 23 & Session 7: Session 8:
February 02, 2024 From Output Measurement to Impact Management
Impact Valuation

Session 5: Session 6:
Beginning the Corporate Social Irresponsibility Business Ethics
sustainability
transformation
Session 3: Session 4:
January 09 & 10, 2024 Regulatory Landscape and Sustainability and CSR Strategy
Sustainability Disclosure

Fundamental concepts Session 1: Session 2:


January 08, 2024 Introduction to Sustainability Introduction to CSR

January 09, 2024 2


Guiding Questions

1. What are the current regulatory developments


in sustainability and sustainability reporting?
2. How can the most important sustainability
topics of a company be identifyed for reporting
(Materiality Assessment)?
3. How do external stakeholders (esp. the
financial market) look at corporate sustainability
performance?

Who of you has read the


sustainability report of your
company?

January 09, 2024 3


The alphabet soup of sustainability

How is the new level playing field going to look like?

January 09, 2024 4


The number of globally adopted laws and guidelines on
climate change has increased significantly

January 09, 2024 5


Sustainability-related regulation over time

EU
2015 Green
2005 Deal EU 2021 CSRD
2019 Taxonomy 2023

2017 NFRD ISSB


SFDR 2019 2022
Standard
2018 2023/24

CSDDD
LkSG 2022 2024

January 09, 2024 6


The European Green Deal

January 09, 2024 7


Legislation and frameworks to achieve the objectives of
the Green Deal

Directives and regulations that require Guidelines and requirements that


procedural changes in companies impose reporting obligations

Corporate Sustainability Due Diligence Directive CSRD

Sustainable Corporate Governance Initiative ESRS

EU Whistleblowing Directive EU Taxonomy

EU Directive on Combating Forced Labour and Machine Readability (European Single Electronic
Child Labour Format ESEF)
Source: EU Commission (n.d.)
January 09, 2024 8
Corporate Sustainability Due Diligence Directive
(CSDDD)
Under discussion, if implemented
it needs to be incorporated in the entire value chain
If adopted, the CSDDD would introduce requirements for companies to identify and prevent, bring to an end, or mitigate the
actual and potential impacts of their activities on the environment and on human rights abuses.
Companies would..
• be obliged to conduct due diligence on their own operations, on the activities of their subsidiaries, and other entities in
their value chains with which they have direct and indirect established business relationships.
• need to develop and implement ‘prevention action plans’, obtain contractual assurances from their direct business
partners that they will comply with the plans, and subsequently verify compliance.

Who would be affected?


1. EU companies with > 500 employees and a net worldwide turnover of > EUR 150 million in the
last financial year.
2. EU companies with > 250 employees and a net worldwide turnover of > EUR 40 million, provided at least 50% of this
turnover was generated in a high-impact sector.
3. non-EU companies that generate a net turnover of > EUR 150 million in the EU
in the last financial year.
4. non-EU companies that generate a net turnover of > EUR 40 million in the EU,
provided at least 50% of worldwide turnover was generated in a high-impact sector.

Source: https://kpmg.com/xx/en/home/insights/2023/02/the-eu-corporate-sustainability-due-diligence-directive.html

January 09, 2024 9


What is the current status of the CSDDD?

• The CSDDD was proposed by the European


Commission in February 2022 and is moving
through the European Union legislative
process.
• In December 2022, the EU Council finalized
its position, materially amending the scope of
the Commission's proposal and suggesting a
less punitive approach to the enforcement
measures.
• On December 14, 2023, the EU Council and
the European Parliament reached a
provisional political agreement on the CSDDD.

Image: https://europe.unc.edu/toolkits/chapter-3/
Source:
https://www.consilium.europa.eu/en/press/press-
releases/2023/12/14/corporate-sustainability-due-diligence-council-and-
parliament-strike-deal-to-protect-environment-and-human-rights/
https://kpmg.com/xx/en/home/insights/2023/02/the-eu-corporate-
sustainability-due-diligence-directive.html

January 09, 2024 10


Established Reporting Standards

applicable for medium sized enterprises


and a simplified version of GRI

Global Reporting Initiative UN Global Compact (UNGC) German Sustainability Code


The GRI develops guidelines for the The UNGC is a strategic initiative for The Sustainability Code includes 20
preparation of sustainability reports. companies that commit to aligning criteria and provides guidance for the
The guidelines are developed in an their business activities and strategies strategic orientation of companies
international dialogue with with 10 recognized principles in the with regard to sustainability concept,
representatives of business, trade areas of labor standards, process management, ecology and
unions, society and science and are environmental protection, human social issues.
subsequently published. The rights and anti corruption. Companies
guidelines complement sustainability that have committed must regularly The Code provides a framework for
management and controlling in the submit a Communication on Progress reporting and can be used to prepare
company. (CoP) on the implementation of the a non-financial statement in the sense
10 principles. of the CSR / Sustainability reporting
obligations.
Source: IHK Frankfurt am Main: https://www.frankfurt-main.ihk.de/hauptnavigation/wirtschaftspolitik/csr-und-nachhaltigkeit/csr-berichtspflicht-5284482

January 09, 2024 11


The EU Taxonomy

The EU Taxonomy is classification system for


organizations to identify which of their economic
activities, or the economic activities they invest in, can be
deemed environmentally sustainable.

Objective of the legislation: Only climate change mitigation and climate


To reward and promote environmentally friendly change adaptation are defined
business practices and technologies through an
Six climate and environmental objectives in focus:
investment focus.

This classification provides ...


• Clear rules and framework conditions for when
a company operates in a sustainable or
environmentally friendly manner.
• Opportunity for companies to differentiate
themselves positively from competitors and
thus benefit from higher investments.

Source: https://eu-taxonomy.info/de/info/eu-taxonomie-grundlagen

January 09, 2024 12


Who needs to report according to EU Taxonomy?

The EU taxonomy regulation for the objective


assessment of the sustainability of economic
activities considers different circumstances and
obligations for different economic actors. It is
divided into the following three groups:

1. Companies (over 500 employees) that fall


under the non-financial reporting directive
(NFRD)
2. Financial market participant, including
occupational pension providers, that offer and
distribute financial products in the EU
(including those from outside the EU)
3. EU and its member states when setting
public measures, standards or labels for green
financial products or (corporate) bonds

Source: https://eu-taxonomy.info/info/eu-taxonomy-for-companies

January 09, 2024 13


Assessment for EU Taxonomy-alignment

The assessment for EU Taxonomy alignment follows two main steps:


Check whether your activities are in EU taxonomy list!

1 Determining Taxonomy eligibility 2 Determining Taxonomy alignment

minimum social safeguards


Source: Arnold et al. (2023) based on European Commission (2023)

January 09, 2024 14


The process for determining Taxonomy alignment?

For the first time, the EU taxonomy clearly


specifies which economic activities are
sustainable and which are not.

Economic activities are sustainable if they are identified by the Taxonomy as relevant activities and:

1. Substantially contribute* 2. Do no significant harm 3. Comply with minimum


to one in six impact areas & in any of the six impact areas Reporting
& (social) safeguards

Six impact areas subject to Principles 1+2 Guidelines behind Principle 3 % Turnover
1. Climate change mitigation 4. Transition to a circular economy
1. UN Human Rights Principles
2. Climate change adaptation 5. Pollution prevention and control % OpEx
2. OECD Guidelines for MNEs
3. Protection of water & 6. Biodiversity and ecosystem
marine resources protection/restoration 3. EU laws, were stricter and
applicable % CapEx

*technical screening criteria linked to the relevant activities define whether an activity substantially contributes to an environmental objective.
Source: Technical expert group on sustainable finance (TEG) (2020).

January 09, 2024 15


Companies Report Taxonomy-Alignment in Three
Different Segments: Turnover, CapEx, OpEx

Example: a company has two business activities, manufacturing windmills and extracting oil & gas via fracking.

Windmill ✓ Sub.
% of turnover

50% ✓ DNSH ✓ Minimum


manufacturing contribution requirements 50% of the
1 company’s turnover is
50% X Not sub. taxonomy-aligned
Fracking
contribution
Comply with
Technical screening Substantially Do no
minimum
criteria: contribute significant harm
safeguards 75% of the company’s
CapEx is taxonomy-
% investments

Expand windmill ✓ Sub. ✓ DNSH ✓ Minimum


operations
75% aligned
contribution requirements
2 X Not sub.
+ maintenance and
Explore new gas 25% restoration of the
fields contribution windmills are taxonomy-
aligned OpEx.

Source: based on Sustainalize (2021)

January 09, 2024 16


Introduction of the Corporate Sustainability Reporting
Directive (CSRD)

The CSRD significantly expands existing rules on non-financial reporting.


All companies listed on an EU-regulated market (with the exception of micro-enterprises) are covered by the
new reporting obligation. In addition, all non-capital market-oriented companies are covered by the CSRD if
they fulfill two of the following three criteria:
• Balance sheet total > 20 million euros
• Net sales > 40 million euros It is estimated that this would affect around
• Number of employees > 250 50,000 companies in the EU, 15,000 of
them in Germany alone.

The "phase-in" of the CSRD:


• From 2024: all companies that fall under the NFRD
• From 2025: large companies (see criteria above)
• From 2026: listed SMEs as well as small and non-complex credit institutions
and captive insurance companies (with opt-out for transitional period until 2028)

Source: KPMG: https://home.kpmg/de/de/home/themen/uebersicht/esg/corporate-sustainability-reporting-directive.html

January 09, 2024 17


Corporate Sustainability Reporting Directive

The CSRD requires disclosures in reporting on:


• Sustainability targets (e.g. Net Zero Commitment)
• the role of the administrative, management and supervisory
bodies in relation to sustainability issues
• the company's main adverse impacts (e.g. in connection with the
company's value chain)
• intangible resources not yet recognized in the balance sheet (e.g.
intellectual, human, social and relationship capital)

In future, sustainability information should only be disclosed in the


management report (i.e. no separate sustainability report).The new
CSRD follows a double materiality perspective.
The CSRD requires companies to collect
completely new data and often demands this
from their suppliers (including SMEs).

Source: KPMG: https://home.kpmg/de/de/home/themen/uebersicht/esg/corporate-sustainability-reporting-directive.html

January 09, 2024 18


European Sustainability Reporting Standards (ESRS)
EU companies need to use ESRS for reporting

• The ESRS standards are reporting standards


for sustainability within the EU. The standards
are mandatory for all companies which fall
under the CSRD (e.g., >250 employees).
• The ESRS aim to advance the scope and
quality of corporate sustainability reporting
and promote sustainable development through
transparency. Stakeholders, especially
investors, other companies and society should
gain better insights into the business practices
of companies.
• On July 31, 2023, the European Commission
adopted the first set of ESRS. First reporting in
2025 for the fiscal year 2024.

Source: https://denkstatt.eu/esrs-standards-explained/

January 09, 2024 19


The ESRS specify the detailed reporting
requirements as set out by CSRD
• The sector-agnostics standards of the ESRS include 2 cross-cutting and 10 topical standards
• In future, addtional sector-specific standards will be published as well as more details for SMEs.
• These standards will be complemented by further guidance documents.

Image: pwc.com

January 09, 2024 20


ESRS: additional phase-in provisions

EU Commission (2023);
Image: pwc.com
January 09, 2024 21
Next steps around ESRS

• ESRS-Sector specific Standards:


most likely until June 2026

• EFRAG Q&A Platform


https://survey.alchemer.eu/s3/90634629/EFRAG-ESRS-Q-A-platform

• Implementation Guidance for Materiality Assessment,


Value Chain, and required datapoints
https://www.efrag.org/News/Public-471/Publication-of-the-3-Draft-EFRAG-ESRS-IG-
documents-EFRAG-IG-1-to-3-?AspxAutoDetectCookieSupport=1

January 09, 2024 22


CSRD vs. ESRS

What is the difference between CSRD and ESRS and how are they connected?

CSRD ESRS

A regulatory directive that describes the A framework for the disclosure of sustainability
sustainability disclosure requirements for large information that must be used by companies
and listed companies in the EU. This is about the covered by the CSRD. This is about the how and
why, the who, and the when. what.

Source: https://nordesg.de/der-unterschied-zwischen-csrd-und-esrs/

January 09, 2024 23


General Disclosure (ESRS 2)
All companies need to report on that!

ESRS 2 explains the disclosure requirements for the preparation of a


sustainability statement and applies to all companies, regardless of
their activities and sustainability relevance.
Information must also be provided on the extent to which the value chain
(upstream and downstream) is covered in the statement.

In addition, explanations are required on the topics of


• Governance: role of administrative/ management/ supervisory bodies, incentive systems, due diligence,
risk management
• Strategy: business model, stakeholders, risks and opportunities
• Materiality assessment
Information on ESRS 2 needs to be
• Key Performance Indicators, and
disclosed, independed of the results of
• Targets. the materiality assessment!

Source: https://www.roedl.com/insights/esg-news/2023-4/esrs-1-and-2-materiality-
reporting-structure-disclosure-requirements

January 09, 2024 24


IFRS Sustainability Disclosure Standard (IFRS ISSB)
ESRS can be used for multiple stakeholders whereas IFRS are used for financial investors
(sustainability related financial information)

IFRS Sustainability Disclosure Standard (IFRS ISSB)


• Global baseline for sustainability reporting standards
• Investor-oriented disclosure similar to financial reporting
• Merges different initiatives for sustainability disclosure, such as CDSB, SASB,
VRF, and IIRC
• In June 2023 the first two standards were published — one on general
sustainability-related disclosures and one on climate

January 09, 2024 25


IFRS
General requirements and climate-related disclosure

General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1),


which is the core framework for the disclosure of material information about sustainability-
related risks and opportunities across an entity’s value chain.
Two step process to identify sustainability risks and opportunities:
• Step 1: helps identify sustainability-related risks and opportunities that could affect an entity’s
prospects over the short, medium and long term.
• Step 2 helps determine the disclosures to provide in relation to the sustainability-related risks
and opportunities identified in step 1.

Climate-related Disclosures (IFRS S2), which is the first thematic standard, and sets out
requirements for entities to disclose information about climate-related risks and opportunities.
The cross-industry metrics include disclosures on greenhouse gas (GHG) emissions, transition risks,
physical risks, climate-related opportunities, capital deployment, internal carbon prices and
remuneration.
For example, when providing GHG emissions disclosures, IFRS S2 requires an entity to measure
and disclose its Scope 1, Scope 2 and Scope 3 GHG emissions in accordance with the GHG
Protocol
Source: PwC (2023): https://viewpoint.pwc.com/dt/gx/en/pwc/in_briefs/in_briefs_INT/in_briefs_INT/ifrs-sustainability-disclosure-
standards-have-been-released.html#pwc-topic.dita_8332d937-1a03-4a07-a8b4-26a7ac4f9f29

January 09, 2024 26


Interoperability of different standards
GRI, ESRS,IFRS ARE THREE MAJOR REPORTING
STANDARDS.
But all three standards don’t overlap
• Sustainability Reporting Challenges:
• Different reporting frameworks pose varied
questions and disclosure requirements across
ESG themes.
• Some frameworks emphasize specific areas
while overlooking others.
• Diversity in Reporting:
• Frameworks vary, leading to diverse questions
and criteria for ESG reporting.
• Not all themes receive equal attention,
creating disparities.
• Positive Note:
• Fundamental disclosure requirements offer
universal applicability across frameworks.
• Challenges Ahead:
• Disparities exist, with some questions having
no counterparts in other reporting standards.
• Achieving uniformity in ESG reporting remains
a challenge. Source: https://nordesg.de/interoperabilitaet-von-reporting-frameworks-esrs-gri-
tcfd-ifrs/

January 09, 2024 27


Guiding Questions

1. What are the current regulatory developments


in sustainability and sustainability reporting?
2. How can the most important sustainability
topics of a company be identifyed for
reporting (Materiality Assessment)?
3. How do external stakeholders (esp. the
financial market) look at corporate sustainability
performance?

January 09, 2024 28


Materiality analysis – Determining reporting
relevant topics

Understanding the context of Identification of the list of Determination of the final list
A the stakeholder engagement B potential material C of material matters based on
strategy sustainability matters & IROs the materiality assessment

• analysis of the undertaking’s activities, • Leverage from existing processes of • Impact materiality assessment
business model, business identification and analysis of impacts, • Financial materiality assessment
relationships and value chain risks, and opportunities (IROs)
• Aggregation of the outcome of impact
• definition of time horizon to be used in • Identification of potential material materiality and financial materiality
the materiality assessment process sustainability matters and their related assessment and consideration of their
• analysis of the undertaking’s relevant IROs interaction
legal and regulatory landscape
• definition of the stakeholder
engagement strategy

Early involvement of the


Source: EFRAG (2023): Implementation guidance for the materiality assessment
auditor is essential.
January 09, 2024 29
Double Materiality

Financial Materiality Impact Materiality

Company impacts
on the environment
e.g., financial risks or society can be e.g., impacts from emissions
through climate change financial material. to the environment
Company Society and Company Society and
Environment Environment

The Outside-in-Perspective captures the The Inside-Out-Perspective covers the


financial risks and opportunities that significant impacts that the organization can
sustainability matters can have on the have on people or the environment.
organization.

Primary audience: Primary audience:


Investors Consumers, Society, Employees, Investors

https://www.finchandbeak.com/1713/double-materiality-tips-for-practical.htm January 09, 2024 30


Step C: Determination of the final list of material
matters based on an assessment of the materiality of
the impacts, risks and opportunities

Impact materiality assessment


• Apply objective criteria using appropriate quantitative and/or qualitative thresholds to assess the materiality of current and
potential impacts, which is based on severity
• Go through the list of potentially material impacts defined in step B and apply the criteria determined by severity, which is
• Scale (e.g., extend of positive or negative effect),
• Scope (e.g., number of people affected), and
• Irremediable character of the impact (extent to which the impact can be remediated)
• Stakeholder engagement informs this step of the materiality assessment as key stakeholders could assess, validate and ensure
completeness of the final list of material impacts

Financial materiality assessment


• Material risks and opportunities generally derive either from impacts or from dependencies. To assess their materiality,
appropriate quantitative and/or qualitative thresholds based upon anticipated financial effects in terms of performance, financial
situation, cash flows, access to and cost of capital are used.
• Sustainability risks and opportunities are assessed based on their likelihood of occurrence and the potential magnitude of
their financial effects in the short-, medium-, and long-term. Therefore, the undertaking shall go through the list of
potentially material risks and opportunities from step B above and apply an objective set of thresholds for likelihood and
magnitude.
• In addition, the undertaking shall consider the list of potential material impacts to assess whether they are sources of
current or potential risks and opportunities.

Source: EFRAG (2023): Implementation guidance for the materiality assessment

January 09, 2024 31


Visualizing the results – Impact Materiality
Focus on the topics in the red area

Scale: How grave the impact is (i.e.,


extent of infringement of access to basic
life necessities or freedoms (e.g.,
education, livelihood etc.);

Scope: How widespread the impact is


(i.e., number of individuals affected or the
extent of the environmental damage); and

Irremediable character: The extent to


which the impact can be remediated (e.g.,
through compensation or restitution;
whether the people affected can be
restored to their exercise of the right in
question). The underlying question is: Are
there any limits on the ability to restore the
environment or those affected to a
situation at least the same as, or
equivalent to, their situation
before the negative impact?

Source: EFRAG (2023): Implementation guidance for the materiality assessment

January 09, 2024 32


Examples for how the outcome of a materiality
assessment could be illustrated

Source: https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/risk/deloitte-nl-risk-double-materiality.pdf

January 09, 2024 33


Example for Materiality Matrix: Telefónica

Source: Telefónica – Consolidated Management Report 2021:


https://www.telefonica.com/en/shareholders-investors/financial-
reports/integrated-annual-report/

January 09, 2024 34


From Sustainainability matters to impacts,
risks and opportunities

Source: EFRAG (2023): Implementation guidance for the materiality assessment

January 09, 2024 35


Reporting Standards and Materiality

Financial Materiality Impact Materiality

January 09, 2024 36


Guiding Questions

1. What are the current regulatory developments


in sustainability and sustainability reporting?
2. How can the most important sustainability
topics of a company be identifyed for reporting
(Materiality Assessment)?
3. How do external stakeholders (esp. the
financial market) look at corporate
sustainability performance?

January 09, 2024 37


ESG Ratings

large companies

ESG ratings describe a scoring framework


through which a company’s performance on
Environmental, Social, and Governmental
factors is evaluated and measured in a
systematic way to yield a combined score.

Such ESG ratings are used to form investment


decisions and thereby significantly influence a
company’s ability to finance themselves.

Source: Pagano, Sinclair, & Yang 2018


… and many more.
January 09, 2024 38
ESG Ratings

Source: https://www.spglobal.com/esg/solutions/data-intelligence-esg-scores

January 09, 2024 39


The „ESG Data Gap“

Shortcomings in ESG ratings:


• Companies with a high score from one rater often receive a middling or low score from another rater
• Differences in the definitions of ESG constructs and differences in the methods applied for measuring ESG
performance of companies
• Lack of transparency in what constitutes ESG performance and how ESG performance is measured,
including information sources used

Implications for ESG reporting/ratings:


• New data sources are needed in order to understand the actual impact a company has on society.
• Companies need to communicate and report to their external stakeholders, whether their businesses are fit
to thrive in a future world transformed by climate change and financed by investors who care about social
impact.

Sources:
https://hbr.org/2020/01/larry-fink-isnt-going-to-read-your-sustainability-report
https://www.institutionalinvestor.com/article/b1hm5ghqtxj9s7/Where-ESG-Fails January 09, 2024 40
https://jwm.pm-research.com/content/24/1/49.abstract
Sustainable Finance Disclosure Regulation (SFDR)

The SFDR is the EU regulation aiming to regulate sustainable investments –


making it mandatory for all financial market participants such as banks,
investment firms, and pension funds, to disclose the negative impact their
financial products have on the people and planet in a standardized format.

SFDR disclosure requirements can be divided into organization-level reporting and fund/product-level reporting.

Organization-Level Reporting: Fund/Product Level:


• Negative impacts on ESG factors (e.g., water • Impact of sustainability risk on financial
usage, energy consumption, biodiversity, performance.
human rights). • Consideration of negative impacts on
• Consideration of ESG risks in investment sustainability risk.
decision-making. • Monitoring, measuring, and assessing
• Alignment of remuneration policies with sustainability impact for products labeled as
sustainability integration. sustainable investments.
Source:
https://finance.ec.europa.eu/sustainable-finance/disclosures/sustainability-related-disclosure-financial-services-sector_en
https://esgtree.com/a-brief-guide-to-sfdr-reporting-and-compliance/
https://blog.worldfavor.com/sfdr-what-are-the-pai-indicators

January 09, 2024 41


SFDR – Principal Adverse Impact

The Principal Adverse Impact (PAI) statement is an


integral part of SFDR. It consists of 18 mandatory
List of mandatory PAIs:
indicators, and two elective ones chosen from 46
options. These indicators consist of quantitative
questions about the potentially negative impact of a
fund or organization on ESG factors.

PAIs should be disclosed in the following,


independently applicable, ways:
1. Disclosure on an entity level (article 4 SFDR), by
publishing an annual PAI statement on the
website, this requirement applies to both financial
market participants and financial advisers; and
2. Disclosure on a product level (article 7 SFDR),
by publishing PAI information in pre-contractual
financial product documentation, such as fund
information or prospectuses, this requirement
applies to financial market participants only. Source:
https://www2.deloitte.com/nl/nl/pages/legal/articles/pai-disclosures-under-the-sfdr.html
https://blog.worldfavor.com/sfdr-what-are-the-pai-indicators

January 09, 2024 42


Time for Discussion!

Helpful guidance provided by multiple organizations:


In your group, conduct a materiality
assessment and be prepared to share your
results with others.
• Based on the information available on the
homepage of the company you’re assigned to,
what are the material sustainability matters
(from both, a financial and impact materiality
perspective)?
• Please indicate whether the identified
sustainability matters can be categorized as
impacts and/or risks/opportunities?
• How would you illustrate your results in a
materiality matrix?
https://media-publications.bcg.com/New-Double-Materiality-Assessment-
final-21.02.23.pdf
https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/risk/deloitte-
nl-risk-double-materiality.pdf
https://www.efrag.org/Assets/Download?assetUrl=%2Fsites%2Fwebpublis
hing%2FSiteAssets%2FDraft%2520EFRAG%2520IG%25201%2520MAIG
%2520231222.pdf

January 09, 2024 43


Source: https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/risk/deloitte-nl-risk-double-materiality.pdf

January 09, 2024 44


THANK YOU
VERY MUCH!

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