43. For material sub-topics the undertaking shall disclose:

AR 36. The human rights incidents in scope for this disclosure are those that relate to not respecting internationally recognised human rights as defined in

Directive (EU) 2022/2464 (CSRD), Article 29b(2)(b)(iii).

These incidents are understood as the number of substantiated instances registered by the undertaking of:

For the purpose of this disclosure, only substantiated and verified instances are to be reported. An instance is substantiated when it is evidenced by objective, factual and verifiable information. An instance is verified when a Court, the OECD or an administrative authority has made a formal finding that the instance occurred. Not all ongoing judicial or non-judicial proceedings, and not all other instances registered by the undertaking, are necessarily substantiated instances.

AR 38. When applying the filter of information materiality

(paragraph 23 of ESRS 1 General Requirements) to the information about incidents referred to under

paragraph 43(a) and (b), the undertaking’s assessment is primarily based on the severity of the impacts on its own workforce.

AR 39. If the undertaking considers that changes in human rights incidents and incidents of discrimination are relevant for understanding the

effectiveness and availability of channels to raise concerns or needs, including grievance mechanisms, it may cross-reference paragraph 43(b) and paragraph 14.

AR 40. The way the undertaking has addressed or is addressing incidents referred to in paragraph 43(a) and (b) may be cross-referenced to information disclosed in accordance with ESRS S1-3.