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

Transcription

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 N Background Information For the purpose of analysis of this consultation you want to be identified as -single choice reply- Other Other, please specify -open reply- Representative organisation Name(s) (of respondent and of your organisation / company) -open reply- Cooperatives Europe Country where your organisation / company is located -single choice reply- BE - Belgique / België Please provide the name and location of parent company Your address Cooperatives Europe European Cooperatives House Ave Milcamps, Bruxelles Tel: Fax: Your address: -open reply- a.mathis@coopseurope.coop Short description of the general activity of your organisation / company: Cooperatives Europe is the biggest membership organisation in Europe promoting the co-operative model of enterprise for sustainable economic progress with social objectives. It represents a force for economic and social change of * 160,000 co-operative enterprises * 123 million members * 5.4 million Jobs 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 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

2 Page 2 of 5 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- Poor 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. Cooperatives Europe being a representative organization within EU, we cannot take position from a national membership perspective. Nevertheless, we can mention the regime of disclosure applicable in France since It made mandatory for enterprises on the stock exchange the publication of a report, on a yearly basis, containing non-financial indicators. The regulation specifies required indicators and items. The Grenelle2 regulation (art.225) will extend the obligation to all enterprises whatever the type of enterprise- of more than 500 employees, and 50 million euros turnover or 43 million euros in total assets. This regulation has been agreed with consensus, and is, to our knowledge, the most ambitious existing one in Europe at the moment. We would advise the European Commission to consider the French regulation, its contents, and the way it has been set up, as it seems to answer to a certain number of elements mentioned in this questionnaire. 2. Have you evaluated the effects, No and costs and benefits, of any current corporate disclosure of environmental and social information? -single choice reply- Cooperatives Europe has not yet undertaken such a study. Nonetheless some of our members have been involved since longtime on such similar processes or at least in CSR reporting. This work internally benefit to - The thinking and introspection on the impact of the enterprise on its social and natural environment, allowing the definition of potential actions - The mobilization of employees around social and environmental issues - The image of the company Nevertheless we should consider that disclosure of ESG information -if important- is not an end in itself and should not imply too much administrative burden. In order to be efficient and thrifty for enterprises -especially for the smallest ones that cannot dedicate specific resources (human, technical) to CSR policy- it should focus on a reasonable list of targeted indicators and information to deliver. It could be interesting to proportion the number of indicators to the size of the company, as it is generally the case for the balance sheet and income statement (simplified for SMEs). A specific regime for SMEs is required. 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 minimum scenario from a European perspective should to set up: - a harmonized framework for ESG disclosure - containing a list of o General indicators applicable to all sectors that would make possible comparisons of data from one company to another o Sectoral indicators Whether the European regime of disclosure would be mandatory or optional, in our view, the following scenario might be considered: 1. A battery of (for example 300) general indicators into which companies should -according to their size- freely make a selection of: a. 25 indicators for Small companies b. 50 indicators for Medium-sized companies c. 100 indicators for Large companies 2. Sectoral indicators could be proposed too, but given the diversity of sectors and entrepreneurial forms, they might remain at the discretion of companies. 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 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.: R&D expenditure).

3 Page 3 of 5 In our view the question is not to know if the company has a CSR policy, but rather on which fields the company has to disclose and be transparent. Whenever some European reports are asked at EU level, then it should be on precised items and decided at EU level in order to make possible a comparison between companies. A specific regime for SMEs should be required. 5. In your opinion, for a EU measure Key Performance Indicators (KPIs) 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- General for all economic sectors Sector specific 5b) Please indicate which indicators you would consider to be the most relevant for all economic sectors: Introductory remarks: - In our view the question is not to settle vague principles, but to set precise indicators for a reporting framework. - Quantitative indicators that could be supplemented with qualitative explanations, depending on the kind of information required would certainly make easier materiality and comparability. - The definition of KPIs should be clarified. We are in favor of indicators in so far as they mean raw data. But we cannot judge the performance of the company regarding these indicators, as the performance only depends on the strategy and objectives of the company. The respect of the law is not about the performance of the company, as the law has to be respected. So, before developing performance indicators, let s start with keyindicators based on raw data. - We can only judge of the performance comparing the indicator to the objectives settled by the company (if we want to judge the indicator regarding what is required by the law, it is no more a performance indicator). Indicators should be both general and sectors-specific. - Common indicators are needed whatever the sector is, as trans-sector comparisons can be useful and meaning. - In addition, sectors could be encouraged to develop specific indicators, adapted to their specific sector and/or form of enterprise. Indeed it is important to consider the diversity of the types of business and legal forms, differentiating for example private stock companies from co-operatives societies where ownership is collective and power is exercised democratically and where the vision and practice of CSR are not the same. 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. General principles and indicators have been yet developed within existing framework (including in national regulation like in France with the New economic regulation and Grenelle 2, and in Denmark). It would not be efficient to start from scratch, so these experiences should inspire the Commission. In order to not reinventing the wheel, and as many organizations and experts and enterprises including cooperatives- have yet worked to define and propose indicators, the process of determining the appropriate indicators should be built upon the work already developed. We think that the most appropriate and efficient way to identify relevant and consensual indicators should be a consultation within the Multistakeholder Forum on CSR, as it includes organizations from all areas that represent the diversity of point of views. 7. In your opinion, should companies No opinion be required to disclose the steps they take to fulfill the corporate responsibility to respect human rights? -single choice reply- Cooperative are deeply attached to the respect and defense of human rights, and promote them through their funding principles (collective ownership, democratic participation), and action in favor of social, economic and human development, emancipation of people and especially women. A description of the processes companies set in order to monitor the respect of human rights cannot be the guarantee that companies act in a good way. Nevertheless the European Commission could play a strategic role in: - developing a framework that defines human rights expectations - translating these expectations into 3 to 5 items (ex. freedom of Association, no child labor, freedom of conscience, non-discrimination regarding age, gender, political and religious beliefs )

4 Page 4 of 5 that companies should integrate into their ESG reporting, and that would incite companies to conduct human rights due diligence There again, the Commission should take care of not generating administrative burden for small and medium enterprises, and should mainly focus on companies who operates through subsidiaries in non- EU and countries with low regulation in matters of human rights. 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- Some sectors are yet obliged by regulations to give information on these issues or similar ones especially the banking sector. Information about how companies deal with corruption and bribery could be interesting to include to indicators, for companies that operate in sensitive areas or in countries where there is no specific laws on these issues. 9. In your opinion, what companies Other should be required to disclose nonfinancial information (check only one box)? -single choice reply- Other, please specify -open reply- If mandatory, disclosure of non-financial information should apply to companies whether they are listed or nonlisted in the stock market. We are in favor of a reporting adapted to the size of the company: the larger the firm is, the more it must be able to report. The volume of indicators should be progressive, considering the size of the company, for example: - 25 general indicators for Small companies - 50 general indicators for Medium-sized companies general indicators for Large companies To which sectoral indicators would be added. We insist on the need for a specific regime for SMEs. 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. Institutional investors, giving their important role in the collection of savings and their presence on financial markets, in our view, should disclose on how they contribute to environmental and social issues, for example on their policy regarding: - solidarity savings - socially responsible investment - criteria and sectors of exclusion 11. In your opinion, should European policy promote the concept of "integrated reporting"? No opinion 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. We are in favor of an integrated report, in so far as it means to publish financial and non-financial information in a single document (apriori into the existing economic company report). But we do not believe that it is possible to establish a causal relationship between financial and nonfinancial reporting at this stage. Not only because social and environmental responsibility is a necessity regardless of the financial aspects, but also because mixing

5 Page 5 of 5 financial with non-financial indicators seems premature, and sometimes irrelevant. The work on ESG key indicators at the European level should be more advanced before reaching a conclusive result. 12. In your opinion, should disclosed 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. An external auditing of the information published could be interesting as it will encourage companies to improve and make reliable their reporting. Nevertheless - The skills and independency of auditors should be verified. The answers to who will be the auditors and how far they will be able to guarantee their independence remain unclear. - Moreover, we are concerned about the cost of auditing for SMEs. - Elsewhere, it is unclear if these auditors would know the specificities of co-operative enterprises. This audit should be based only on specific raw data, figures, and statistics. 13. If you have relevant documents I attach additional documents you want to share with us, please attach them here. (optional) -multiple PRINT EXPORT RECORD