At the general level, the content of the report will depend on the results of the materiality study conducted in accordance with the double materiality principle (impact materiality and financial materiality). In addition, some of the disclosure requirements we will have to implement regardless of the results of the study are Disclosure Requirements required by other EU regulations.
Sector standards are created not for all companies, but for those that belong to specific industries in the economy. These standards will include additional disclosure requirements, enriching or detailing what each company must report. Working on the first standards for two sectors (Mining, Quarrying and Coal Mining and Oil and Gas), Sustainability Reporting TEG and the Sustainability Reporting Board must determine how companies should select information that fulfills sectoral disclosure requirements. Final decisions have not yet been made, but the two bodies are currently considering two approaches.
The first approach is to provide a list of sustainability issues that are typically material to companies in a given sector in a sector standard. This list would have to be taken into account by the company applying the standard in its materiality study. However, the results of the study do not have to coincide with this list, as it may turn out that despite belonging to a sector, certain issues listed therein are not relevant to that particular company. In such a case, these issues would simply be omitted from the report.
The second approach is to designate a certain small group of issues that are always relevant to companies belonging to a particular sector or subsector. If it found, as a result of its investigation, that there were issues on this list that were not relevant to its particular case, it would have to briefly comment and justify such a conclusion.
I am in favor of the second approach, because it increases information transparency, readability and clarity of the report for recipients, and contributes to countering greenwashing involving, among other things, the concealment of important information. Consider such an example: the regulator recognizes that for companies belonging to the Mining, Quarrying and Coal Mining sector, the issue of health and safety is always relevant. A certain company belonging to this sector conducts its materiality study, which concludes that OSH is not a material issue in its case. In the first approach, the company simply does not report indicators related to EHS, and does not have to provide any explanation as to why it does not. In the second approach, the company would have to explain why health and safety issues are not relevant in its case (e.g., the company is only engaged in technical inspections of stone extraction equipment, and the employees conducting these inspections operate on machines that are turned off, outside of the plant's normal operating cycle, and for this reason there are no risks to their health and life). I believe that it is the latter approach that is appropriate, as it does not add an undue burden to the company in preparing the report, but allows it to provide the report recipients with valuable information.
Further discussions between Sustainability Reporting TEG and the Sustainability Reporting Board will continue in the coming weeks, which should result in a final approach to materiality in sector standards.
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