ESRS disclosure requirements covered by the entity’s sustainability statement (IRO‑2)
- ESRS:
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Disclosure requirements in ESRS covered by the undertaking’s sustainability statementIRO-2Disclosure requirements in ESRS covered by the undertaking’s sustainability statement
| Index code | Name | Place in report section |
|---|---|---|
| ESRS 2 | General disclosure | General disclosure (Sustainability of the Group) |
| BP-1 | Basis for preparation of sustainability statement | Basis for preparation of sustainability statement (BP-1) |
| BP-2 | Disclosure in relation to special circumstances | Disclosure in relation to special circumstances (BP-2) |
| GOV-1 | The role of the administrative, management and supervisory bodies |
The role of the administrative, management and supervisory bodies (GOV-1) |
| GOV-2 | Information provided to the entity’s administrative, management and supervisory bodies and the sustainability issues they undertake | Information provided to and sustainability matters addressed by the Management Board and the Supervisory Board (GOV-2) |
| GOV-3 | Including sustainability-related outcomes in incentive systems |
Integration of sustainability-related performance in incentive schemes (GOV-3) |
| GOV-4 | Due diligence statement | Statement on due diligence (GOV-4) |
| GOV-5 | Risk management and internal controls over sustainability reporting |
Risk management and internal controls over sustainability reporting (GOV-5) |
| SBM-1 | Strategy, business model and value chain | Strategy, business model and value chain (SBM-1) |
| SBM-2 | Stakeholder interests and opinions | Interests and views of stakeholders (SBM-2) |
| SBM-3 | Significant impacts, risks and opportunities and their interrelationship with the strategy and the business model | Material impacts, risks and opportunities and their interaction with strategy and business model (SBM-3) |
| IRO-1 | Description of processes to identify the assessment of significant impacts, significant risks and significant opportunities | Description of the processes to identify and assess material impacts, risks and opportunities (IRO-1) |
| IRO-2 | ESRS disclosure requirements covered by the entity’s sustainability statement |
ESRS disclosure requirements covered by the entity’s sustainability statement (IRO-2) |
| ESRS E1 | Climate change | Environmental information – climate change (ESRS E1) |
| ESRS 2 GOV-3 | Including sustainability-related outcomes in incentive schemes |
Integration of sustainability-related performance in incentive schemes (GOV-3) |
| E1-1 | Transformation plan for climate change mitigation | Transition plan for climate change mitigation (E1-1) |
| ESRS 2 SBM-3 | Significant impacts, risks and opportunities and their interrelationship with the strategy and the business model | Material impacts, risks and opportunities and their interaction with strategy and business model (SBM-3) |
| ESRS 2 IRO-1 | Description of processes for identifying and assessing climate-related significant impacts, risks and opportunities | Description of the processes to identify and assess material impacts, risks and opportunities (IRO-1) |
| E1-2 | Policies related to climate change mitigation and adaptation | Policies related to climate change mitigation and adaptation (E1-2) |
| E1-3 | Action and resources in relation to climate policy | Actions and resources in relation to climate change policies (E1-3) |
| E1-4 | Climate change mitigation and adaptation objectives | Targets related to climate change mitigation and adaptation (E1-4) |
| E1-5 | Energy consumption and energy mix | Energy consumption and energy mix (E1-5) |
| E1-6 | GHG removal and reduction projects using carbon credits | Gross Scope 1, 2 and 3 greenhouse gas emissions and total greenhouse gas emissions (E1-6) |
| E1-7 | GHG removal and reduction projects using carbon credits | Other climate-related disclosures (E1-7, E1-8, E1-9) |
| E1-8 | Internal determination of greenhouse gas emission charges | Other climate-related disclosures (E1-7, E1-8, E1-9) Disclosure does not apply to the Group |
| E1-9 | Anticipated financial impacts from significant physical and transition risks and potential climaterelated opportunities |
Other climate-related disclosures (E1-7, E1-8, E1-9) Phase-in |
| ESRS S1 | Own workforce | Our People – own workforce (ESRS S1) |
| ESRS 2 SBM-2 | Stakeholder interests and opinions | Interests and views of stakeholders (SBM-2) |
| ESRS 2 SBM-3 | Significant impacts, risks and opportunities and their interrelationship with the strategy and the business model | Material impacts, risks and opportunities and their interaction with strategy and business model (SBM-3) |
| S1-1 | Policies related to own workforce | Policies related to own workforce (S1-1) |
| S1-2 | Procedures for working with your own employees and employee representatives to influence | Involvement of employees and procedures for working with employees’ representatives (S1-2) |
| S1-3 | Mitigation processes and channels for reporting problems by unit staff |
Processes to remediate negative impacts and channels for own workforce to raise concerns (S1-3) |
| S1-4 | Taking action on significant impacts on its own workforce and using approaches to mitigate significant risks and exploit significant opportunities associated with its own workforce, and the effectiveness of these actions | Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions (S1-4) (MDR-A) |
| S1-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S1-5) |
| S1-6 | Characteristics of the Undertaking’s Employees | Characteristics of employees (S1- 6) |
| S1-7 | Characteristics of non-employees in the undertaking’s own workforce |
Characteristics of non-employees in the Group’s own workforce (S1-7) |
| S1-8 | Collective bargaining coverage and social dialogue | Collective bargaining coverage and social dialogue (S1-8) |
| S1-9 | Diversity metrics | Diversity metrics (S1-9) |
| S1-10 | Adequate wages | Adequate wages (S1-10) |
| S1-11 | Social protection | Social protection (S1-11) |
| S1-12 | Persons with disabilities | Persons with disabilities (S1-12) |
| S1-13 | Training and skills development indicators | Training and Skills Development metrics (S1-13) |
| S1-14 | Health and safety metrics | Health and safety metrics (S1-14) |
| S1-15 | Work-life balance | Work-life balance metrics (S1-15) |
| S1-16 | Remuneration metrics (pay gap and total remuneration) |
Remuneration metrics (pay gap and total remuneration) |
| S1-17 | Incidents, complaints and serious human rights impacts |
Incidents, complaints and severe human rights impacts (S1-17) |
| ESRS S3 | Affected communities | Affected communities (ESRS S3) |
| ESRS 2 SBM-2 | Stakeholder interests and opinions | Interests and views of stakeholders (SBM-2) |
| ESRS 2 SBM-3 | Significant impacts, risks and opportunities and their interrelationship with the strategy and the business model | Material impacts, risks and opportunities and their interaction with strategy and business model (SBM-3) |
| S3-1 | Policies related to affected communities | Policies related to affected communities (S3-1) |
| S3-2 | Processes for engaging with affected communities about impacts | Processes for engaging with affected communities about impacts (S3-2) |
| S3-3 | Processes to remediate negative impacts and channels for affected communities to raise concerns |
Processes to remediate negative impacts and channels for affected communities to raise concerns (S3-3) |
| S3-4 | Taking action on material impacts on affected communities, and approaches to mitigating material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions | Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions (S3-4) (MDR-A) |
| S3-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S3-5) |
| ESRS S4 | Consumers and end-users | Our customers – consumers and end-users (ESRS S4) |
| ESRS 2 SBM-2 | Stakeholder interests and opinions | Interests and views of stakeholders (SBM-2) |
| ESRS 2 SBM-2 | Significant impacts, risks and opportunities and their interrelationship with the strategy and the business model | Material impacts, risks and opportunities and their interaction with strategy and business model (SBM-3) |
| S4-1 | Policies related to consumers and end-users | Policies related to consumers and end-users (S4-1) |
| S4-2 | Processes for engaging with consumers and endusers about impact | Processes for engaging with consumers and end-users about impacts (S4-2) |
| S4-3 | Processes to remediate negative impacts and channels for consumers and end-users to raise concerns |
Processes to remediate negative impacts and channels for consumers and endusers to raise concerns (S4-3) |
| S4-4 | Taking action on significant impacts on consumers and end-users and applying approaches to manage significant risks and opportunities related to consumers and end-users, and the effectiveness of these actions | Taking action on material impacts on consumers and end- users, and approaches to mitigating material risks and pursuing material opportunities related to consumers and end-users and effectiveness of those actions (S4-4) (MDR-A) |
| S4-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S4-5) |
| ESRS G1 | Business Conduct | Governance information – Business conduct (G1) |
| ESRS 2 GOV-1 | The role of the administrative, supervisory and management bodies |
The Role of the Management Board and the Supervisory Board (GOV-1) |
| ESRS 2 IRO-1 | Description of processes to identify and assess significant impacts, risks and opportunities |
Description of the processes to identify and assess material impacts, risks and opportunities (IRO-1) |
| G1-1 | Business conduct policies and corporate culture | Business conduct policies and corporate culture (G1-1) |
| G1-2 | Management of relationships with suppliers | Management of relationships with suppliers (G1-2) and payment practices (G1-6) |
| G1-3 | Prevention and detection of corruption and bribery | Prevention and detection of corruption and bribery (G1-3) |
| G1-4 | Incidents of corruption or bribery | Incidents of corruption or bribery (G1-4) |
| G1-5 | Political influence and lobbying activities | Disclosure does not apply to the Group |
| G1-6 | Payment practices | Management of relationships with suppliers (G1-2) and payment practices (G1-6) |
| Disclosure Requirement and related datapoint |
SFDR reference | Pillar 3 reference | Benchmark Regulation reference | EU Climate Law reference |
|---|---|---|---|---|
| ESRS 2 GOV-1 Board’s gender diversity paragraph 21 (d) |
Indicator number 13 of Table #1 of Annex 1 |
Commission Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS 2 GOV-1 Percentage of board members who are independent paragraph 21 (e) |
Delegated Regulation (EU)2020/1816, Annex II |
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| ESRS 2 GOV-4 Statement on due diligence paragraph 30 |
Indicator number 10 Table #3 of Annex 1 | |||
| ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities paragraph 40 (d) i |
Indicators number 4 Table #1 of Annex 1 | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Table 1: Qualitative information on Environmental risk and Table 2: Qualitative information on Social risk |
Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS 2 SBM-1 Involvement in activities related to chemical production paragraph 40 (d) ii |
Indicator number 9 Table #2 of Annex 1 | Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS 2 SBM-1 Involvement in activities related to Controversial weapons paragraph 40 (d) iii |
Indicator number 14 Table #1 of Annex 1 | Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco paragraph 40 (d) iv |
Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS E1-1 Transition plan to reach climate neutrality by 2050 paragraph 14 |
Regulation (EU) 2021/1119, Article 2(1) | |||
| ESRS E1-1 Undertakings excluded from Paris-aligned benchmarks paragraph 16 (g) |
Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity |
Delegated Regulation (EU) 2020/1818, Article12.1 (d) to (g), and Article 12.2 |
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| ESRS E1-4 GHG emission reduction targets paragraph 34 |
Indicator number 4 Table #2 of Annex 1 | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics |
Delegated Regulation (EU) 2020/1818, Article 6 |
|
| ESRS E1-5 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) paragraph 38 |
Indicator number 5 Table #1 and Indicator n. 5 Table #2 of Annex 1 |
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| ESRS E1-5 Energy consumption and mix paragraph 37 |
Indicator number 5 Table #1 of Annex 1 | |||
| ESRS E1-5 Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43 |
Indicator number 6 Table #1 of Annex 1 | |||
| ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44 |
Indicators number 1and 2 Table #1 of Annex 1 |
Article 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate change transition risk: Credit quality of exposures by sector, emissions and residual maturity |
Delegated Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1) |
|
| ESRS E1-6 Gross GHG emissions intensity paragraphs 53 to 55 |
Indicators number 3 Table #1 of Annex 1 | Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metrics |
Delegated Regulation (EU) 2020/1818, Article 8(1) |
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| ESRS E1-7 GHG removals and carbon credits paragraph 56 |
Regulation (EU) 2021/1119, Article 2(1) | |||
| ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66 |
Delegated Regulation (EU) 2020/1818, Annex II Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a) |
Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Paragraphs 46 and 47; Template 5: Banking book – Climate change physical risk: Exposures subject to physical risk. |
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| ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c). |
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| ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy- efficiency classes paragraph 67 (c). |
Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Paragraph 34;Template 2:Banking book -Climate Change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral |
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| ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69 |
Delegated Regulation (EU) 2020/1818, Annex II |
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| ESRS E2-4 Amount of each pollutant listed in Annex II of the EPRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil, paragraph 28 |
Indicator number 8 Table #1 of Annex 1 Indicator number 2 Table #2 of Annex 1 Indicator number 1 Table #2 of Annex 1 Indicator number 3 Table #2 of Annex 1 |
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| ESRS E3-1 Water and marine resources paragraph 9 |
Indicator number 7 Table #2 of Annex 1 | |||
| ESRS E3-1 Dedicated policy paragraph 13 |
Indicator number 8 Table 2 of Annex 1 | |||
| ESRS E3-1 Sustainable oceans and seas paragraph 14 |
Indicator number 12 Table #2 of Annex 1 | |||
| ESRS E3-4 Total water recycled and reused paragraph 28 (c) |
Indicator number 6.2 Table #2 of Annex 1 | |||
| ESRS E3-4 Total water consumption in m3 per net revenue on own operations paragraph 29 |
Indicator number 6.1 Table #2 of Annex 1 | |||
| ESRS 2 IRO1-E4 paragraph 16 (a) i |
Indicator number 7 Table #1 of Annex 1 | |||
| ESRS 2 IRO1-E4 E4 paragraph 16 (b) |
Indicator number 10 Table #2 of Annex 1 | |||
| ESRS 2 IRO1-E4 paragraph 16 (c) |
Indicator number 14 Table #2 of Annex 1 | |||
| ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) |
Indicator number 11 Table #2 of Annex 1 | |||
| ESRS E4-2 Sustainable oceans / seas practices or Policies paragraph 24 (c) |
Indicator number 12 Table #2 of Annex 1 | |||
| ESRS E4-2 Policies to address deforestation paragraph 24 (d) |
Indicator number 15 Table #2 of Annex 1 | |||
| ESRS E5-5 Non-recycled waste paragraph 37 (d) |
Indicator number 13 Table #2 of Annex 1 | |||
| ESRS E5-5 Hazardous waste and radioactive waste paragraph 39 |
Indicator number 9 Table #1 of Annex 1 | |||
| ESRS 2 SBM-3-S1 Risk of incidents of forced labour paragraph 14 (f) |
Indicator number 13 Table #3 of Annex I |
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| ESRS 2 SBM-3-S1 Risk of incidents of child labour paragraph 14 (g) |
Indicator number 12 Table #3 of Annex I | |||
| ESRS S1-1 Human rights policy Commitments paragraph 20 |
Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex I |
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| ESRS S1-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 21 |
Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS S1-1 processes and measures for preventing trafficking in human beings paragraph 22 |
Indicator number 11 Table #3 of Annex I | |||
| ESRS S1-1 workplace accident prevention policy or management system paragraph 23 |
Indicator number 1 Table #3 of Annex I | |||
| ESRS S1-3 grievance/complaints handling mechanisms paragraph 32 (c) |
Indicator number 5 Table #3 of Annex I | |||
| ESRS S1-14 Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c) |
Indicator number 2 Table #3 of Annex I | Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e) |
Indicator number 3 Table #3 of Annex I | |||
| ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a) |
Indicator number 12 Table #1 of Annex I | Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b) |
Indicator number 8 Table #3 of Annex I | |||
| ESRS S1-17 Incidents of discrimination paragraph 103 (a) |
Indicator number 7 Table #3 of Annex I | |||
| ESRS S1-17 Nonrespect of UNGPs on Business and Human Rights and OECD paragraph 104 (a) |
Indicator number 10 Table #1 and Indicator n. 14 Table #3 of Annex I |
Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818 Art 12 (1) |
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| ESRS 2 SBM-3-S2 Significant risk of child labour or forced labour in the value chain paragraph 11 (b) |
Indicators number 12 and n. 13 Table #3 of Annex I |
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| ESRS S2-1 Human rights policy Commitments paragraph 17 |
Indicator number 9 Table #3 and Indicator n. 11 Table #1 of Annex 1 |
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| ESRS S2-1 Policies related to value chain workers paragraph 18 |
Indicator number 11 and n. 4 Table #3 of Annex 1 |
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| ESRS S2-1 Nonrespect of UNGPs on Business and Human Rights principles and OECD guidelines paragraph 19 |
Indicator number 10 Table #1 of Annex 1 | Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1) |
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| ESRS S2-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19 |
Delegated Regulation (EU) 2020/1816,Annex II |
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| ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36 |
Indicator number 14 Table #3 of Annex 1 | |||
| ESRS S3-1 Human rights policy commitments paragraph 16 |
Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1 |
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| ESRS S3-1 non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17 |
Indicator number 10 Table #1 Annex 1 | Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art. 12 (1) |
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| ESRS S3-4 Human rights issues and incidents paragraph 36 |
Indicator number 14 Table #3 of Annex 1 | |||
| ESRS S4-1 Policies related to consumers and end-users paragraph 16 |
Indicator number 9 Table #3 and Indicator number 11 Table #1 of Annex 1 |
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| ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17 |
Indicator number 10 Table #1 of Annex 1 |
Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art. 12 (1) |
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| ESRS S4-4 Human rights issues and incidents paragraph 35 |
Indicator number 14 Table #3 of Annex 1 | |||
| ESRS G1-1 United Nations Convention against corruption paragraph 10 (b) |
Indicator number 15 Table #3 of Annex 1 | |||
| ESRS G1-1 Protection of whistleblowers paragraph 10 (d) |
Indicator number 6 Table #3 of Annex 1 | |||
| ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a) |
Indicator number 17 Table #3 of Annex 1 | Delegated Regulation (EU) 2020/1816, Annex II |
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| ESRS G1-4 Standards of anticorruption and anti- bribery paragraph 24 (b) |
Indicator number 16 Table #3 of Annex 1 |
