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CSRD/ESRS Reports Reviewed by BWD
General disclosures
List of disclosures covered in each report
Maersk
Tryg
Kemira
Risk assessment process
Maersk
Maersk used inherent risk score
Tryg
Tryg accounted for mitigating actions, suggesting this is consistent with guidance available at the time
They also note that “gross risk” determines materiality
Netcompany
Clarifies that material matters are material “if not managed adequately”
StoraEnso
StoraEnso uses a specific monetary threshold for financial risks.
Determining material information
Tryg
Netcompany
SBM Strategy Business Model Reporting
Maersk
Maersk integrates SBM into opening content on business model
Netcompany
Acknowledges that climate-related issues do not affect the strategy or business model
StoraEnso
Example of business model diagram
For the interaction between IROs and business model, StoraEnso has opted for a summary of SBM-3 AND included detailed descriptions related to the IRO at the beginning of each topic standards
Fiskars
Kemira
Sanofi
Brought in the six capitals framework from Integrated Reporting
Stakeholder engagement reporting
Maersk
Maersk includes “citizenship” (chaity, philanthropy, etc.) as a component of its stakeholder engagement approach.
Tryg
Tryg notes no external consultations performed for some topics in the materiality assessment
Disclosure that stakeholders were not involved in target setting
Netcompany
summary of stakeholder engagement in materiality assessment
example of specific consultation for environmental issues related to a protected area
StoraEnso
Example of stakeholder engagement table split by affected stakeholder and users of sustainability report
StoraEnso only consulted with employee for affected stakeholders
Fiskars
Stakeholder engagement in maeriality assessment
For workers in the value chain, Fiskars notes worker interviews during audits
Kemira
Novo Nordisk
Novo Nordisk has deemed S3 immaterial and mentions not engaging affected communities
Table of stakeholders:
Orsted
Sanofi
Describes how the business model was amended in response to stakeholder views
Material IRO description
Maersk
Maersk has used its own wording
Maersk splits issues into three levels of priority: strategic, prioritized, foundational.
Maersk has a table for SBM-3 paragraph 48 disclosures
Novo Nordisk
Novo Nordisk describes “material topics”, which include impacts, risks and opportunities
Tryg
Netcompany
Narrative on social matters considered material or not material
Carlsberg (2023 report)
Orsted
Example of presenting E1
Table with all standards
Fiskars
Kemira
Merck
Positive impacts and opportunities
Fiskars
Positive impacts and opportunities pertaining to circularity
Positive impacts and opportunities pertaining to own workforce
StoraEnso
Example of linking financial opportunities to dependencies on environment
Examples of training/development, work rights, and diversity interpreted as positive impacts
Tryg
Materiality assessment process (ESRS 2 IRO-1)
StoraEnso
A solid overview of the materiality assessment process for environmental topics
An example of when an incident may result in the need to update the assessment results
Fiskars
Explained that process built on assessments over several years - 2022 for impact materiality, then 2023
Orsted
Process description for immaterial topics
General DMA process and methodology
Process for E5 (material)
Sanofi
acknowledged that risks are assessed without mitigating measures
Relied on past stakeholder engagement activities in DMA
Scoring of IROs
StoraEnso
Good example of severity and irremediable character being weighted higher for impacts
StoraEnso has aligned their materiality threshold with the EU Taxonomy
Fiskars
Kemira
Sanofi
“Squared” severity and magnitude. Also confirmed that the highest rating from the severity sub-criteria was used (as opposed to an average)
Current financial effects
Netcompany
StoraEnso
Example of current financial effects of material opportunities and reference to financial statements
BASF
Description of class settlement (page 411)
Sanofi
Does not expect material adjustment to financial statements
Resilience analysis
Netcompany
Fiskars
Climate resilience
Biodiversity/ecosystems/nature resilience
Kemira - biodiversity resilience
Policy disclosures
Netcompany
Netcompany includes a policy overview to address MDR-P
Also provides policy coverage by matter
Fiskars
Mentions that it does not have a policy on climate adaptation
Kemira
Uses a table for MDR-P for key business conduct policies
Merck
Uses table for MDR-P
Targets
Maersk
Maersk mentions some targets are “recurring” - could be a way to disclose BAU initiatives as a “target”...
Netcompany
Discloses that they have not set sustainability targets
Kemira - internal indicators instead of targets
Biodiversity indicators are present (but not disclosed)
Kemira - provided a table of MDR-T requirements
Expenditures and resourcing for actions
Netcompany
Maersk
Kemira
Kemira does not appear to disclose expenditure for climate actions
BASF
Sanofi
Merck
Entity-specific metric examples
Maersk
Maersk elects to disclose an entity-specific “efficiency in ocean” metric.
Responsible tax metric
Operations covered by risk assessment on corruption and ethics
Data and AI ethics training
StoraEnso
StoraEnso has prepared entity-specific disclosures on biodiversity
Sanofi
Identified entity-specific IRO
Uncertainties and estimates (BP-2)
Maersk
Novo Nordisk
provides a blanket statement up front, and then indicates estimates in the “accounting policies” in each section of the statement.
StoraEnso
A general statement of uncertainty and estimation, where further details are presented at the accounting principle for each metric.
Excluding specific disclosures
Tryg
Fiskars
Fiskars elected to not disclose several indicators under the sensitive information clause
Unable to report Information from suppliers operations
Kemira - has not yet created impact metrics for biodiversity
Incorporation by reference
Maersk example table
Information provided to and sustainability matters addressed by the undertaking’s administrative, management, and supervisory bodies (GOV-2)
StoraEnso
Good table summarizing the sustainability matters addressed by the board committee
Sanofi
How Board and committees take IROs into account. Notable that the meeting date does not necessarily need to be in the reporting period
Statement on due diligence (GOV-4)
Example of a table to summarize where in the sustainability statement that elements of due diligence is embedded
Fiskars
Kemira
Time horizon
StoraEnso
StoraEnso has defined their own time horizons
Reporting boundary/consolidation
Kemira
“Associates” not included in sustainability statement
Value chain visual
Orsted
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