ESRS Standard
ESRS Standard
The term"Policy" is synonymous with the term"Policy", which is used within the German version of the ESRS Standard.
28 The company shall disclose its actions with respect to Material Impacts on Consumers and End-users and to manage Material risks and take advantage of Material opportunities related to Consumers and End-users and the effectiveness of these actions and approaches.
29 This disclosure requirement has two Targets: The first is to provide an understanding of all actions and initiatives the company is taking to
a) works to prevent, mitigate and improve significant negative impacts on Consumers and/or End-users, or
b) seeks to achieve positive material impacts on Consumers and/or End-users.
On the other hand, it should provide an understanding of how the company manages Material risks and takes advantage of Material opportunities related to Consumers and/or End-users.
30. the company provides a summary description of the action plans and resources related to the management of its Material Impacts, Risks and Opportunities in relation to Consumers and End-users in accordance with ESRS 2 MDR-A Actions and resources related to Material Sustainability Aspects.
31 With regard to material impacts, the company describes the following:
(a) what actions have been taken, are planned or are underway to prevent, mitigate or ameliorate any significant adverse impacts on Consumers and/or End-users,
b) whether and how it has taken actions to remedy or enable the remedy of an actual material impact,
(c) any additional actions or initiatives taken primarily to contribute positively to better social outcomes for Consumers and/or End-users; and
(d) how it tracks and evaluates the effectiveness of these actions and initiatives in achieving the desired outcomes for Consumers and/or End-users.
32. in relation to paragraph 28, the company shall describe the following:
(a) the processes it uses to determine what actions are necessary and appropriate to respond to specific actual or potential negative impacts on Consumers and/or End-users,
(b) its approaches to taking action in relation to specific material adverse impacts on Consumers and/or End-users, including any actions related to its own practices in relation to product design, marketing or sales, and whether further actions are required in relation to industry and cooperation with other relevant parties; and
c) how it ensures that procedures to implement or enable remedial action in the event of material adverse impacts are available and effective in terms of their implementation and outcomes.
33. with regard to Material risks and Opportunities, the company describes,
a) what actions are planned or have been taken to mitigate material risks to the company arising from its Impacts and Dependencies related to Consumers and/or End-users and how it tracks effectiveness in practice; and
b) What actions are planned or have been taken to address material opportunities for the company related to Consumers and/or End-users.
34. the company discloses whether and how it takes actions to prevent its own practices from causing or contributing to material adverse impacts on Consumers and/or End-users, including, where appropriate, its practices in relation to marketing, sales and data use. This may include disclosure of the approach taken to address tensions between avoiding or mitigating Impact materiality and other business pressures.
(35) In making this disclosure, the company shall also consider whether serious human rights issues and incidents have been reported in relation to its Consumers and/or End-users and, if so, disclose them. (126)
36. where the company assesses the effectiveness of an action by setting a Targets, it shall take into account the ESRS 2 MDR-T Tracking the effectiveness of policies and actions through Targets when providing the information required under paragraph 31(d).
37. the company shall specify the means allocated to the management of its Impact materiality, providing information that enables Users to understand how the Impact materiality is managed.
Application Requirements (AR)
Application Requirements (AR)
AR 25. it may take some time to understand the negative impacts and how the organization may be associated with them through the downstream Value chain, and to identify appropriate responses and put them into practice. In this regard, the company shall consider the following:
(a) its general and specific approaches to addressing material adverse impacts,
b) its initiatives to contribute to additional material positive impacts,
c) how far it has progressed with its efforts during the reporting period and
d) its targets for continuous improvement.
AR 26 The appropriate actions may vary depending on whether the company causes or contributes to significant impacts or the significant impacts are directly linked to its activities, products or services through a business relationship.
AR 27. as material negative impacts on Consumers and/or End-users that occur during the reporting period may also be associated with companies or activities outside its direct control, the company may indicate whether and how it intends to use its leverage within its relevant Business relationships to address these impacts. This may include the use of business leverage (e.g. enforcing contractual requirements within business relationships or implementing incentives), other forms of leverage within the business relationship (e.g. training or capacity building on the intended use of products or sales practices), or collaboration with peer companies or other actors (e.g. responsible marketing or product safety initiatives).
AR 28 If the company discloses its participation in an industry or multi-stakeholder initiative as part of its actions to address material negative impacts, it may also disclose how the relevant material impacts will be addressed as part of the initiative and its own participation. Under ESRS S4-5, it may provide information on the relevant Targets of the initiative and progress towards achieving them.
AR 29 When disclosing whether and how the company considers the actual and potential impacts on Consumers and/or End-users when making decisions to terminate Business relationships and whether and how it seeks to ameliorate any negative impacts of termination, the company may provide examples.
AR 30 If the company discloses how it tracks the effectiveness of actions taken to address material impacts during the reporting period, it can provide any lessons learned from the previous and current reporting periods.
AR 31 The processes for tracking the effectiveness of Actions may include internal or external audits or reviews, legal proceedings and/or related court rulings, impact assessments, measurement systems, stakeholder feedback, Grievance mechanisms, external performance ratings and benchmarks.
AR 32 Reporting on effectiveness should enable an understanding of the linkages between the actions taken by the organization and the effective management of impacts.
AR 33. with respect to initiatives or practices that are based on Consumer and/or End-users ' needs and the level of their implementation, the company may disclose the following:
(a) information on whether and to what extent Consumers and/or End-users and Legitimate representatives or their Credible proxies are involved in decisions on the design and implementation of these programs or practices; and
(b) information on the intended or achieved positive outcomes of these programs or practices for Consumers and/or End-users.
AR 34 The company may indicate whether initiatives or practices whose primary objective is to achieve positive impacts on Consumers and/or End-users are also designed to support the achievement of one or more of the United Nations Sustainable Development Goals (SDGs). For example, as part of a commitment to advance Sustainable Development Goal 3 "Ensure healthy lives and promote well-being for all at all ages", the company could actively work to make its products less Dependencies and harmful to physical and mental health.
AR 35. when stating the intended positive results of the company's actions for Consumers and/or End-users, distinguish between evidence that specific activities have taken place (e.g. that x Consumers have received information on healthy eating habits) and evidence of actual results for Consumers and/or End-users (e.g. that x Consumers have adopted healthier eating habits).
AR 36. when disclosing whether initiatives or practices also play a role in mitigating material negative impacts, the company may consider, for example, programs aimed at promoting increased awareness of the risk of online fraud in order to reduce the number of instances of breaches of End-users ' privacy.
AR 37. when disclosing the material risks and opportunities associated with the company's Impacts or Dependencies in relation to Consumers and/or End-users, the company may consider the following:
(a) Risks related to the company's impacts on Consumers and/or End-users may include reputational risks and legal risks if poorly designed or defective products result in injury or death.
b) Risks associated with the Company's Dependencies on Consumers and/or End-users may include loss of business continuity if Consumers are unable to afford certain products or services due to an economic crisis.
c) Opportunities related to the company's Impacts on Consumers and/or End-users may include market differentiation and greater customer attraction by offering secure products or privacy-friendly services; and
d) Opportunities related to the company's Dependencies on Consumers and/or End-users may include building a loyal future consumer base by ensuring, for example, that LGBTQI individuals are respected and that the company's sales practices do not exclude these individuals from the products or services offered.
AR 38 When making disclosures about whether Dependencies become Risks, the company shall consider external developments.
AR 39 When disclosing policies, actions, means and targets related to the management of Material Risks and Opportunities, the company may cross-reference its disclosures on policies, actions, means and targets related to these impacts in cases where risks and opportunities arise from Material Impacts.
AR 40 The entity shall consider the extent to which its processes for managing material risks related to Consumers and/or End-users are integrated into its existing risk management processes.
AR 41 When disclosing the resources allocated to managing material impacts, the company may indicate which internal functions are involved in managing impacts and the types of actions it takes to address negative impacts and drive positive impacts.
Example from past practice
Example 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.
S4-4 - Actions taken in relation to Customers and Consumers
Basic services and responsible financial offering
We ensure that all customers have access to essential financial services and safe forms of investment. This also includes offers for people on lower incomes. Our branch network has been adapted to meet changing needs, supplemented by digital access channels such as online and mobile banking. Debt advice and free financial education services help customers to plan their budgets responsibly.
Barrier-free access
We have further expanded barrier-free access to our branches, self-service devices and digital services. Almost all branches are wheelchair accessible and our ATMs offer tactile and acoustic support.
Data protection and information security
Data protection is an integral part of our business strategy. Our processes and control systems are regularly reviewed and adapted to technological developments to ensure the protection of customer data.
Access and advice
We operate a dense branch network with personal service and self-service sites, even in structurally weaker areas. Digital channels such as online banking and apps offer fast and secure solutions, which are supplemented by regular training - especially for older Users.
Promoting financial literacy
We promote financial education for all age groups with offers such as free children's accounts, digital budget planners and target group-specific advice. Our credit advice helps people to make sustainable financial decisions.
Human rights issues
No serious incidents relating to human rights or the treatment of customers were reported in the reporting year.
This article has been machine translated. In case of errors, please contact [email protected].