Assess record for 'Disclosure of Non-Financial Information by Companies'

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1 Page 1 of 5 Assess record for 'Disclosure of Non-Financial Information by Companies' Meta Informations Creation date Last update date User name null Case Number Invitation Ref. Status Background Information For the purpose of analysis of this consultation you want to be identified as -single choice reply- If you are preparer, are you -single choice reply- N Preparer Organisation of companies Name(s) (of respondent and of your organisation / company) -open reply- Inés GARCÍA-PINTOS, CECA (Confederation of the Spanish Savings Banks) Country where your organisation / ES - España company is located -single choice reply- Please provide the name and location of parent company Your address Your address: -open reply- institucionesinternacionales@ceca.es Short description of the general activity of your organisation / company: CECA, the Spanish Confederation of Savings Banks (Cajas de Ahorros) was created in 1928 with the aim to join its members' forces and represent Spanish Savings Banks Sector. CECA is formed of the 34 Spanish Cajas, grouped around 17 groups of Cajas, which are one of the most important players in Spanish financial system: their total assets reached 1,273 billions, 23,695 branches in Spain and 130,433 employees in September Spanish Cajas are credit institutions that act and are organized as private enterprises. They have the legal status of private institutions. Spanish Cajas are independent institutions which compete directly and individually with each other and with other financial institutions and they are free to decide on their territorial expansion. As credit institutions with foundational origins, Cajas pursue the following main objectives: (1) universal provision of financial services; (2) economic efficiency; (3) promotion and competition and avoidance of monopolistic practices; (4) contribution to welfare and redistribution; and (5) promotion of regional and community development. From their inception, Cajas channel their surpluses not allocated to reserves towards projects that fall under their "Obra Social" scheme (community investments projects). Spanish Cajas are subjects to the same legislation that applies to other types of credit institutions (commercial and cooperative banks) in terms of transparency, solvency and consolidation. Is your organisation registered in the Interest Representative Register? If your organisation is not registered, you have the opportunity to register here before you submit your contribution. Responses from organisations not registered will be published separately from the registered organisations. -single choice reply- Please specify the Register ID number

2 Page 2 of 5 in the Interest Representative Register - open reply- Can the Commission contact you if further details on the information you submitted is required? -single choice reply- Publication: Do you object to publication of the personal data on the grounds that such publication would harm your legitimate interests? -multiple Questionnaire 1. How would you consider the current regime of disclosure of nonfinancial information applicable in your country? -single choice reply- Sufficient In replying to this question, please provide information on what way current reporting provides useful information, and to what extent it is sufficiently tailored to the circumstances of the company. Please also comment on whether you find non-financial information useful for the decision-making of a company. The current regime of disclosure, i.e. Accounts Modernisation Directive 2003/51/EC, provides companies with a framework where ESG information is to be disclosed as far as it is consider relevant to understand the performance of the company. We consider this current regime of disclosure as sufficient, since it allows companies to identify risks and relevant issues that impact their business in a significant manner. Companies can therefore carry out their own materiality tests and identify specific issues in terms of sustainability as regards their own strategy and profile. The current regime does not enforce ESG disclosure by reporting companies which leads to very different levels of disclosure by companies. Moreover, the ESG disclosure debate is not yet ripe in many countries. 2. Have you evaluated the effects, No and costs and benefits, of any current corporate disclosure of environmental and social information? -single choice reply- Although ESBG disclosure is considered as highly beneficial, it is difficult to assess the actual benefits in monetary terms. It has obvious benefits in terms of: - increased transparency, - promotion of confidence in our company - better reputation, - establishment of a platform for enhanced dialogue with our stakeholders - presentation of a more comprehensive picture of the companies performance for our stakeholders (including clients and investors), - better knowledge of companies risks and opportunities - anticipation of environmental and social legislation The same applies to costs: - increased need for human and financial resources - more sophisticated information systems - increased exposure to external critics For our companies, benefits largely offset the costs. 3. If you think that the current regime of disclosure of non-financial information should be improved, how do you suggest that this should be done? The provision of a common framework of principles would be useful for the establishment of a level-playing field and in terms of comparison and efficiency. 4. In your opinion, should companies be required to disclose the following (check all relevant boxes): -multiple Whether or not they have a CSR policy, and if they do, how they implement that policy and what the results have been The principal business risks and opportunities arising from social and environmental issues, and how they are taken into account in company strategy. Key information regarding issues such as employee engagement (e.g.: employee training policy, equality and diversity, etc.); customer satisfaction (e.g.: customer loyalty); public perception of the company (e.g.: stakeholder dialogue); environmental policies (e.g.: energy efficiency, waste reduction); and innovation (e.g.:

3 Page 3 of 5 R&D expenditure). We would favour a principles-based approach that may allow companies to identify their risks and opportunities through materiality tests. This will therefore be more relevant and company-specific. On the other hand, we acknowledge the benefits of defining a set of key indicators. This is particularly useful in terms of comparability, although it does not capture relevant issues. Moreover, the identification of a common set of indicators may be a difficult task since most issues are not understood nor implemented the same way across sectors (i.e. carbon emissions). 5. In your opinion, for a EU measure on reporting of non-financial information to achieve materiality and comparability it should be based upon (check all relevant boxes): - multiple 5a) In case you consider that Key Performance Indicators (KPIs) would be useful, would you think that they should be (check all relevant boxes): - multiple choices reply- Principles Key Performance Indicators (KPIs) General for all economic sectors Sector specific 5b) Please indicate which indicators you would consider to be the most relevant for all economic sectors: The list of indicators might differ from regions and time periods, since material issues evolve with time and respond to different geographical specificities. In any case, we would advocate for a sub-set within GRI core indicators. 6. In your opinion, what should be the process to identify relevant principles and/or indicators (whether general or sector-specific)? In replying to this question, please comment on whether the Commission should endorse or make reference to any existing international frameworks (or a part of them), such as Global Reporting Initiative (GRI), UN Global Compact, the OECD Guidelines, ISO 26000, or other frameworks; or whether companies should be required to select relevant indicators together with their investors and other stakeholders and to disclose information according to such indicators, depending on the use that different stakeholders would make of such information. We would definitely advocate for the endorsement of existing international frameworks and particularly GRI and UN Global Compact, that apply to all companies. These guidelines are developed under a multi-stakeholder process (particularly GRI), have already been tested and applied by most reporting companies. Let s not reinvent the wheel! GRI provides also with specific-sector supplements. OECD Guidelines apply only to multinationals. ISO should be seen as a management guideline, not reporting tool. 7. In your opinion, should companies be required to disclose the steps they take to fulfill the corporate responsibility to respect human rights? -single choice reply- Human rights are an international public good. 8. In your opinion, should companies be required to disclose the risks they face and the policies they have in the field of corruption and bribery? -single choice reply- Disclosure of risks and policies related to bribery and corruption is a desirable aim, although rather difficult to implement in practice. This is definitely a risky and sensitive field and therefore not easy to publicly inform about. Before defining any kind of guidelines or requirements in this field, further insight and assessment of the issue is needed. Disclosure of these issues should be used as a means to try and prevent activities in this field. Joint and multi-stakeholder approach is very much welcomed. 9. In your opinion, what companies Medium-sized & Large companies (listed and non-listed) should be required to disclose non-

4 Page 4 of 5 financial information (check only one box)? -single choice reply- 10. In your opinion, should institutional investors be subject to specific or additional disclosure requirements, for example to disclose whether and how they take into account environmental and social issues in their investment decisions? -single choice reply- In replying to this question, please provide information on which issues seem to be the most relevant and why; and which institutional investors should be subject to such an obligation. Ethical, social, economic, environmental and governance issue that have a relevant impact on performance or respond to the values and expectations of trustees. This should particularly apply to: - pension funds, since they manage the funds allocated for future pensions and therefore beneficiaries are specifically interested in getting information on how the fund is managed and the risks involved - sovereign funds, that should ideally be aligned with the values promoted by each country s fundamental legal framework. - investment funds, for the sake of enhanced transparency and commercial issues. 11. In your opinion, should European policy promote the concept of "integrated reporting"? Integrated reporting refers to a report that integrates the company's key financial and non-financial information to show the relationship between financial and non-financial performance (environmental, social, and governance). -single choice reply- In replying to this question, please indicate the advantages and disadvantages of an integrated report, as well as possible specific costs of integrated reporting. Integrated reporting should be considered as the ultimate aim of any initiative regarding ESG disclosure. If ESG parameters are perceived as relevant and having an impact on the sustainability and financial performance of the company, then the link between financial and non-financial issues should be clearly disclosed. Moreover, if the company is one, it makes sense that the disclosure on its performance should be also one. Having said this, we believe that the above is not a simple issue to implement in practical terms. Therefore a framework should be defined and long maturity deadlines established. We would advocate for a large participation of accountants and financial analyst in this exercise 12. In your opinion, should disclosed No opinion non-financial information be audited by external auditors? -single choice reply- In replying to this question please provide any evidence you may have regarding costs of auditing non-financial information, as well as your views on other possible forms of independent reviews besides external auditing. 13. If you have relevant documents you want to share with us, please attach them here. (optional) -multiple Uploaded files: I attach additional documents ESG disclosure.pdf

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