CSRD reference table
In the table below, we present our self-assessment of our implementation of the provisions from the draft European Sustainability Reporting Standards as published by the European Commission on June 9, 2023 in this Report. Where we feel we still have considerable work to do, we clearly indicate so together with our actions to become compliant and our expected timeframe for such actions. 'On track' means that in our opinion, we well positioned to becoming fully compliant once the ESRS are finalised.
# | Description | Status | Reference | Explanatory notes |
ESRS 2: General disclosures (June 2023) | ||||
BP-1 | General basis for preparation of the sustainability statements | On track | pages 123-131 | Our strategy contains both financial and non-financial provisions. We don't disclose some of our financial goals for reasons of confidentiality |
BP-2 | Disclosures in relation to specific circumstances | On track | pages 123-131 | - |
GOV-1 | The role of the administrative, management and supervisory bodies | On track | pages 41-42 | - |
GOV-2 | Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies | On track | pages 41-48 | - |
GOV-3 | Integration of sustainability-related performance in incentive schemes | On track | page 133 | - |
GOV-4 | Statement on sustainability due diligence | On track | page 163 | Reporting to be extended to the whole value chain |
GOV-5 | Risk management and internal controls over sustainability reporting | To be elaborated | pages 123-131 | Basic reporting in place but to be extended with control framework description in 2023/2024 reporting |
SBM-1 | Market position, strategy, business model(s) and value chain | On track | pages 10-19, 28-40, 162-164 | - |
SBM-2 | Interests and views of stakeholders | On track | pages 124-130 | - |
SBM-3 | Material impacts, risks and opportunities and their interaction with strategy and business model(s) | On track | pages 132-161 | To be fortified in communication on our new strategy in our 2023/2024 Report |
IRO-1 | Description of the processes to identify and assess material impacts, risks and opportunities | On track | pages 124-130 | - |
IRO-2 | Disclosure Requirements in ESRS covered by the undertaking’s sustainability statements | On track | pages 123-161 | - |
MDR-P | Policies adopted to manage material sustainability matters | On track | pages 132-161 | Not for all material topics, a comprehensive description of policies is included |
MDR-A | Actions and resources in relation to material sustainability matters | On track | pages 132-161 | Not for all material topics we have set targets as this is not always practical (e.g. for reported ethics cases) |
MDR-M | Metrics in relation to material sustainability matters | Fragmented | pages 132-161 | Not for all material topics metrics have been included in the Report |
MDR-T | Tracking effectiveness of policies and actions through targets | On track | pages 122, 132-161 | Not for all material topics we have set targets as this is not always practical (e.g. for reported ethics cases) |
ESRS E1: Climate change (June 2023) | ||||
E1-1 | Transition plan for climate change mitigation | In progress | pages 132-137 | A fair part of the information required is already included in the Report |
E1-2 | Policies related to climate change mitigation and adaptation | On track | pages 132-137 | - |
E1-3 | Actions and resources in relation to climate change policies | In progress | Not available | Financial implications of our climate strategy are not yet included as we have not yet aligned our eligible EU Taxonomy activities |
E1-4 | Targets related to climate change mitigation and adaptation | On track | pages 132-137 | - |
E1-5 | Energy consumption and mix | On track | pages 132-137 | - |
E1-6 | Gross Scopes 1, 2, 3 and Total GHG emissions | On track | pages 132-137 | Downstream effects still subject of further investigation |
E1-7 | GHG removals and GHG mitigation projects financed through carbon credits | On track | pages 132-137 | - |
E1-8 | Internal carbon pricing | In progress | Not available | Together with DTTL and Deloitte NSE, we are examining the possibilities to introduce an internal carbon price |
E1-9 | Anticipated financial effects from material physical and transition risks and potential climate-related opportunities | In progress | Not available | Deloitte NSE will report on this aspect. Their report will also cover Deloitte Netherlands |
ESRS S1: Own workforce (June 2023) | ||||
S1-1 | Policies related to own workforce | On track | pages 138-150 | - |
S1-2 | Processes for engaging with own workforce and workers’ representatives about impacts | To be developed | pages 138-150 | Currently a fragmented approach around carbon and employee related topics (EVP, I&D, Wellbeing, Learning, DIF). Process to be formalised |
S1-3 | Processes to remediate negative impacts and channels for own workforce to raise concerns | On track | pages 138-150, 156-158 | - |
S1-4 | Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions | On track | pages 138-150 | - |
S1-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Partly on track | pages 138-150 | Not for all aspects targets have been set yet |
S1-6 | Characteristics of the undertaking’s employees | On track | pages 138-150 | - |
S1-7 | Characteristics of non-employees in the undertaking’s own workforce | To be developed | Not available | A section with the characteristics of non employees is to be developed for our 2023/2024 report |
S1-8 | Collective bargaining coverage and social dialogue | To be developed | Not available | A section on our formalised social dialogue is to be developed for our 2023/2024 report |
S1-9 | Diversity metrics | On track | pages 122, 144-147 | - |
S1-10 | Adequate wages | On track | page 141 | - |
S1-11 | Social protection | On track | page 142 | - |
S1-12 | Persons with disabilities | Not available | Not available | Dutch law prevents us from separately registering employees with disabilities |
S1-13 | Training and skills development metrics | On track | pages 144, 149 | - |
S1-14 | Health and safety metrics | On track | page 150 | - |
S1-15 | Work-life balance metrics | On track | pages 142-143 | Only qualitative description |
S1-16 | Remuneration metrics (pay gap and total remuneration) | On track | pages 147, 177 | - |
S1-17 | Incidents, complaints and severe human rights impacts | On track | pages 156-159 | - |
ESRS G1: Business conduct (June 2023) | ||||
G1-1 | Business conduct policies and corporate culture | On track | pages 156-159 | - |
G1-2 | Management of relationships with suppliers | On track | pages 162-164 | - |
G1-3 | Procedures to address corruption and bribery | On track | pages 156-159 | - |
G1-4 | Incidents of corruption or bribery | On track | pages 158-159 | - |
G1-5 | Political influence and lobbying activities | On track | page 156 | - |
G1-6 | Payment practices | On track | page 164 | - |