Table A2.

Example of coding for each category

AspectDefinitionExample (translated into English)
Definition of a large undertaking companyType of company considered as undertaking company[…] 4. In addition to the information specified in Paragraphs 2 and 3 of this Article, large public-interest entities with an average annual number of employees as listed on the past day of the reporting year shall include a social responsibility statement, except for the established case (Lithuania)
Definition of a public interest entityType of company considered as public interest entity[…] b) That they are either considered to be public interest entities following the auditing legislation or, for two consecutive years, they meet, on the closing date of each one, at least two of the circumstances following:
1. That the total of the items of the consolidated asset is greater than 20,000,000 euros
2. That the net amount of the consolidated annual turnover exceeds 40,000,000 euros
3. The average number of workers employed during the year is greater than 250 (Spain)
Reporting frameworkReference to any standard, framework or guideline on NFD[…] (5) At the request of presenting the information mentioned in par. (1), entities may be based on national, Union or international frameworks. In this case, the entities specify the frameworks on which they were based (Romania)
Disclosure formatHow NFD should be presented (e.g. into the Financial Statement, Standalone report)(3) A corporation referred to in paragraph 1 shall also be exempt from the requirement to extend the management report to a non-financial statement where the corporation for the same financial year created a separate non-financial reporting before the Management Report and the following conditions are met:
1. The separate non-financial reporting at least meets the substantive requirements under § 289c and
2. The corporation makes the separate non-financial report available to the public through
a) identification together with the management report according to § 325 or
b) publication on the website of the corporation no later than four months after the closing date and at least 10 years, unless the management report refers to this publication, indicating the reference website. Paragraph 1, Sentence 3 and §§ 289d and 289E apply mutatis mutandis to the separate non-financial report (Germany)
AssuranceProvision of the assurance process on the NFD[…] 6 – In the case of companies that are obliged to present a non-financial statement following Article 66-B or Article 508-G, the statutory auditor accounts should only certify that it or the report separate were presented (Portugal)
Non-compliance penaltiesProvision of penalties in case of lack of compliance or lack of NFD414D Approval and signing of the strategic report
(1) The strategic report must be approved by the board of directors and signed on behalf of the board by a director or the secretary of the company. (2) If a strategic report is approved that does not comply with the requirements of this Act, every director of the company who – (a) knew that it did not comply or was reckless as to whether it complied and (b) failed to take reasonable steps to secure compliance with those requirements or, as the case may be, to prevent the report from being approved, commits an offence. (3) A person guilty of an offence under this section is liable – (a) on conviction on indictment, to a fine and (b) on summary conviction, to a fine not exceeding the statutory maximum. (the UK)
Environmental contentsRequested disclosure on environmental aspects[…] To the extent necessary to understand the development of business, performance, the situation of society and the impact of its activities, relating at least to social, environmental and personnel matters, respect for human rights and the fight against corruption, the annual report, referred to Article 95, includes a declaration which includes the following information:
a) a brief description of the company’s activities;
b) a description of the policies applied by the company in relation to these matters, including the due diligence procedures implemented;
c) the results of these policies;
d) the main risks associated with these matters about the activities of the company, including, where relevant and proportionate, the business relationships, products or services of the company, which are likely to have a negative impact in these area and how the company manages these risks;
e) key performance indicators of a non-financial nature relating to the activities in question (Belgium)
Social contentsRequested disclosure on social aspectsII. – The declaration contains when they are relevant about the main risks or the policies mentioned in I of this article:
A. – For all the companies mentioned in I of article L. 225-102–1, the following information:
1. Social information:
a) Employment:
– the total workforce and the distribution of employees by sex, age and geographic area;
– hiring and dismissals;
– remuneration and their evolution (France)
Personnel contentsRequested disclosure on personnel aspects[…] (b) contain information, to the extent necessary for an understanding of the development, performance, position and impact of its activity relating to, at least, the following matters:

  • • environmental matters;

  • • social and employee matters;

  • • respect for human rights;

  • • bribery and corruption (Ireland)

Human rights contentsRequested disclosure on human rights aspects[…] 6. The large public limited companies comprise entities of public interest, in the sense of Annex A to Law 4308/2014, and which, on the closing date of their balance sheet, exceed the average number of 500 employees during the financial year, including in the management report a non-financial asset voltage containing information, to the extent that is needed to understand evolution, performance, location and impact of activities its, at least about environmental, social on labour issues, respect for rights of human beings, the fight against corruption and on corruption issues (Greece)
Anticorrup-tion and bribery contentsRequested disclosure on anticorruption and bribery aspects[…] f) fight against corruption, both active and passive, with an indication of the tools adopted for this purpose (Italy)
Business model contentsRequested disclosure on business model aspects[…] 1) A brief description of the business model of the capital company, which may include general information on:
the main types of economic activity of the capital company and its geographical area (Latvia)
Policies contentsRequested disclosure on policies issues[…] b. the policy, including the due diligence procedures applied, as well as the results of this policy, about:
(i) environmental, social and human resources matter
(ii) respect for human rights
(iii) fighting corruption and bribery (The Netherlands)
Outcome policies contentsRequested disclosure on outcome policies aspects[…] (2) The information must include –
(a) a brief description of the company’s business model,
(b) a description of the policies pursued by the company in relation to the matters mentioned in subsection (1)(a) to (e) and any due diligence processes implemented by the company in pursuance of those policies,
(c) a description of the outcome of those policies,
(d) a description of the principal risks relating to the matters mentioned in subsection (1) (a) to (e) arising in connection with the company’s operations and, where relevant and proportionate –
(i) a description of its business relationships, products and services which are likely to cause adverse impacts in those areas of risk, and
(ii) a description of how it manages the principal risks and
(e) a description of the non-financial key performance indicators relevant to the company’s business (the UK)
Risks contentsRequested disclosure on risk aspects[…] 5. The main risks that are likely to harm these matters, and how society handles these risks
a. insofar as they arise from the company’s business activities and,
b. if this is relevant and proportionate insofar as they arise from their business relationships, their products or their services … (Austria)
KPIsRequested disclosure on key performance indicator aspects[…] (1) Entities of public interest which, at the balance sheet date, exceed the criterion of having an average number of 500 employees during the financial year include in the directors’ report a statement
non-financial that contains, to the extent that they are necessary to understand the development, performance and position of the entity and the impact of its activity, information on at least environmental, social and personnel aspects, respect for human rights, fighting corruption and bribery, inclusive:
a) a brief description of the business model of the entity;
b) a description of the policies adopted by the entity about these aspects, including the due diligence procedures applied;
c) the results of the respective policies;
d) the main risks related to these aspects arising from the operations of the entity, including, when relevant and proportionate, its business relations, its products or services that could harm the respective fields and the way the entity manages those risks;
e) key non-financial performance indicators relevant to the specific activity of the entity (Romania)
Diversity contentsRequested disclosure on diversity aspects[…] (h) a description of the diversity policy applied to the administrative, management and supervisory bodies of the undertaking, with particular regard to age, gender, academic and professional background, the objectives, how this diversity policy is implemented and the results achieved during the reporting period; description. If no such policy is applied, the statement shall include an explanation (Hungary)
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