ESRS Standard
ESRS Standard
The term"Policy" is synonymous with the term"Policy", which is used within the German version of the ESRS standard.
ESRS 2 - General disclosures
ESRS 2 - General disclosures
10 The disclosures required in this section should be read in conjunction with and made together with the disclosures required in Chapter 4 Management of Impacts, Risks and Opportunities of ESRS 2.
11. the entity explains the process for identifying material Impacts, Risks and Opportunities and provides information on,
a) Whether the company has reviewed its sites and operations to identify its actual and potential Impacts, Risks and Opportunities related to Pollution in its own operations and within its upstream and downstream Value chain , and if so, the methods, assumptions and tools used in the review,
b) whether and how the company has consulted, in particular with affected communities.
Application Requirements (AR)
Application Requirements (AR)
AR 1 When analyzing the materiality of environmental sub-themes, the company assesses the materiality of Pollution in its own operations and in its upstream and downstream Value chain and may consider the following four phases, also known as the LEAP approach:
(a) Phase 1: Identify where in its own operations and within its upstream and downstream Value chain the interface with nature is located,
b) Phase 2: Assessment of Dependencies and Impacts associated with Pollution,
c) Phase 3: Assessment of Material risks and Opportunities, and
d) Phase 4: Preparation and communication of the results of the materiality analysis.
AR 2 The materiality analysisfor the ESRS E2 corresponds to the first three phases of this LEAP approach. The fourth phase is about the results of the process.
AR 3 The process for analyzing the materiality of Impacts, Dependencies, Risks and Opportunities shall take into account the provisions of ESRS 2 IRO-1 Description of the Process for Identifying and Assessing Material Impacts, Risks and Opportunities and IRO-2 Disclosures Covered in the Company's Sustainability statement.
AR 4 The subtopics covered by the materiality analysisin accordance with ESRS E2 include the following:
(a) Air, Water and Soil Pollution (excluding Greenhouse Gas Emissions and Waste), Microplastics and Substances of concern,
b) Dependencies on Ecosystem services that help mitigate Impacts related to Pollution.
AR 5. To identify the location of the interface with nature in its own operations and within its upstream and downstream Value chain, the company may consider the following in Phase 1:
(a) the sites where direct assets are located and where operations and related upstream and downstream activities along the Value chain take place,
b) the sites where emissions of water, Soil and air pollutants take place, and
c) the sectors or business areas associated with these emissions or with the production, use, distribution, marketing and import/export of Microplastics, Substances of Very High Conc ern ( SVHCs ) and Substances of Very High Concern (SVHCs ) in pure form, in mixtures or in articles.
AR 6 Phase 2 refers to the assessment of impacts and Dependencies for each significant Site or sector/business, including by assessing the severity and likelihood of impacts on the environment and human health.
AR 7 In Phase 3, to assess its Material risks and opportunities based on the results of Phases 1 and 2, the company may
a) Identify Transition risks and Opportunities within its own activities and within its upstream and downstream Value chain using the following categories:
i. Policy and legal: e.g. introduction of legislation, exposure to sanctions and litigation (e.g. ecosystem due diligence violations), increased reporting requirements,
ii. Technology: e.g. substitution of products or services with products or services with lower impacts, moving away from Substances of concern,
iii. Market: e.g. shift in supply, demand and financing, volatility or increased cost of some Substances, and
iv. Reputation: e.g. changes in the perception of society, customers or communities as a result of an organization's role in Pollution prevention and control,
b) Identify Physical risks, such as sudden disruptions to access to clean water, acid rain or other pollution incidents that are likely to cause or have caused Pollution, with consequences for the environment and society,
c) Identify Opportunities related to Pollution Prevention and Control, categorized as follows:
i. Resource efficiency: reducing the quantities of Substances used or improving the efficiency of production processes to minimize Impacts,
ii. Markets: e.g. diversification of business activities,
iii. Financing: e.g. access to green funds, bonds or loans,
iv. Resilience: e.g. diversification of Substances used and reduction of Emissions through innovation or technology, and
v. Reputation: positive relationships with stakeholders through a proactive approach to risk management.
AR 8. in the materiality analysis, the company may refer to Commission Recommendation (EU) 2021/2279 on the application of environmental footprint calculation methods for measuring and disclosing the environmental performance of products and organizations within their life cycle.
AR 9 When providing information on the results of the materiality analysis, the company shall consider the following:
(a) a list of sites where Pollution is material to the company's operations and upstream and downstream Value chain; and
b) a list of business activities that are associated with Material Impacts, Risks and Opportunities related to Pollution.
Examples from past practice
Examples from past practice
Examples serve only as an indication of how a disclosure requirement has been reported by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.
E2.IRO-1 - Material impacts and risks associated with pollution
Assessment of Impacts and Risks
We carry out regular controls and assessments to minimize the impacts of pollution on the environment. These assessments are carried out at least once a year as part of our environmental management system and checked by audits in accordance with ISO 14001 standards. Based on these analyses, our organizational units receive a clear overview of their environmental impact and implement targeted actions to reduce it.
In addition, we have established a system to effectively manage exceptional Incidents. We minimize Risks such as the contamination of Surface water, Soil or Groundwater by harmful Substances that are used on our premises or could be released as a result of accidents. In the event of a fire, for example, there is a risk of emissions being released into the air or extinguishing water containing Pollutants contaminating the groundwater or Surface water. We use emergency plans, operating rules and internal standards to ensure that the Impacts of such Incidents are reduced to a minimum.
When dealing with harmful substances, we apply the principle of multi-barrier protection. Areas with higher concentrations of such substances are taken into account in our regularly updated emergency plans. We reduce the risk of Pollutants escaping via the wastewater system by using special devices that can detect and collect these substances. In addition, our in-house fire and rescue service is available around the clock to intervene quickly and in a targeted manner in the event of an emergency.
To further ensure safety, we have introduced a system for evaluating and approving the chemicals we use. Regular maintenance work and leak tests of our installations are essential actions to prevent emergencies and actively fulfill our environmental responsibility.
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