38. Information about policies, actions, metrics and targets shall enable an understanding of the level at which the undertaking manages its material impacts, risks and opportunities. If the undertaking has adopted policies, put in place actions, set targets or uses metrics only for certain aspects of a topic, this shall be reflected in the way the disclosure is prepared and presented, enabling users to understand the specific aspects that are covered.

39. If the undertaking does not have policies, actions, or targets with reference to a topic related to material impacts, risks and opportunities, it shall disclose this fact.

40. The undertaking shall apply the requirements specified in GDR-P, GDR-A, GDR-M and GDR-T when disclosing information either in accordance with a topical standard or on an entity-specific basis about:

AR 30 for para. 38
If the undertaking applies the same policies, actions, metrics or targets across more than one material impact, risk or opportunity, or across more than one topic, it may disclose the information only once, while making clear the scope of its application. It may cross-refer to that information from other locations in the report where relevant. This approach allows the undertaking to present information in a way that is consistent with its management approach.
The undertaking may structure and present its disclosures in a way that reflects the managerial approach based on its management priorities that reflect and align with its strategy and business model.

AR 31 for para. 39
If the undertaking presents its material impacts, risks and opportunities (IRO-2, paragraph 37(a)) and the related topics in a tabular form, it may indicate in the same table the material topics or material impacts, risks and opportunities for which it does not have policies, actions or targets in place by marking them as such in the table.

AR 32 for para. 38
The level of detail provided may vary with regard to each DR, depending on the nature of the material impacts, risks and opportunities in question, and differences in the undertaking’s current approach to their management.
The level of detail provided shall be proportionate to the severity of the impacts, the magnitude of risk or opportunity, or the importance of the impacts, risks and opportunities for the undertaking’s strategy and business model.
The information shall, wherever possible, be specific to the reporting period.
When reporting on policies, actions, metrics and targets, the undertaking shall report relevant information, avoiding information that is boilerplate, and therefore not relevant for users. Excessive detail, especially about common practices which are known to reasonably knowledgeable users, may obscure material information.

AR 33 for para. 40
To avoid duplication and support a coherent narrative, the undertaking may present the description of its material impacts, risks and opportunities, as required under IRO-2, paragraph 37(a), alongside information about the policies, actions, metrics and targets through which it manages those impacts, risks and opportunities.