The Comprehensive Module, includes all the data points from the Basic Module but expands on them with additional sustainability metrics. These extra details are particularly relevant for businesses working with banks, investors, or corporate clients who may require more in-depth reporting. This module provides a more complete ESG overview, making it a strong choice for companies that prioritise transparency, investor confidence, and future regulatory readiness.
The data points:
| B1 – Basis for preparation | ||
| B1 | 24a | Please disclose if you have chosen only to report on the Basic Module or the Basic Module and the Comprehensive Module. |
| B1 | 24b | Have you omitted any disclosure that you deem classified or sensitive information? |
| B1 | 24b | If so, which? |
| B1 | 24c | What is the basis for preparation of your sustainability statement? Has it been prepared on a consolidated or individual basis? |
| B1 | 24d | List the subsidiaries included in your report, including the registered address. |
| B1 | 24e | What is your undertaking's legal form? |
| B1 | 24e | If other, please specify. |
| B1 | 24e | What is your NACE sector classification code? |
| B1 | 24e | What is the size of your balance sheet (in Euro)? |
| B1 | 24e | What is your turnover (in Euro)? |
| B1 | 24e | What is your number of employees? |
| B1 | 24e | Which employee counting methodology do you use - headcount or full-time equivalents? |
| B1 | 24e | |
| B1 | 24e | What is your country of operations and location of significant asset(s)? |
| B1 | 24e | Site |
| B1 | 24e | Address |
| B1 | 24e | Postal code |
| B1 | 24e | City |
| B1 | 24e | Country |
| B1 | 24e | Coordinates (geolocation) |
| B1 | 25 | If you have obtained any sustainability-related certification or label, provide shall a brief description of those (including, where relevant, the issuers of the certification or label, date and rating score).29 |
| B2 – Practices, policies and future initiatives for transitioning towards a more sustainable economy | ||
| B2 | 26a | If your undertaking has put in place specific practices for transitioning towards a more sustainable economy, please describe them. |
| B2 | 26b | If your undertaking has put in place specific policies for transitioning towards a more sustainable economy, please describe them. |
| B2 | 26c | If your undertaking has put in place specific future initiatives for transitioning towards a more sustainable economy, please describe them. |
| B2 | 26d | If your undertaking has put in place specific targets to monitor the implementation of the policies and the progress achieved towards meeting such targets towards a more sustainable economy, please describe them. |
| B2 | G 15a | If your undertaking is a cooperative, it may disclose the effective participation of workers, users or other interested parties or communities in governance. |
| B2 | G 15b | If your undertaking is a cooperative, it may disclose the financial investment in the capital or assets of social economy entities referred to in the Council Recommendation of 29 September 2023 (excluding donations and contributions). |
| B2 | G 15b | If your undertaking is a cooperative, it may disclose any limits to the distribution of profits connected to the mutualistic nature or to the nature of the activities consisting in services of general economic interest (SGEI). |
| C1 – Strategy: Business Model and Sustainability – Related Initiatives | ||
| C1 | 47a | Please disclose a description of significant groups of products and/or services offered. |
| C1 | 47b | Please disclose a description of significant market(s) the undertaking operates in (such as B2B, wholesale, retail, countries). |
| C1 | 47c | Please disclose a a description of main business relationships (such as key suppliers, customers distribution channels and consumers). |
| C1 | 47d | Please disclose if the strategy has key elements that relate to or affect sustainability issues, a brief description of those key elements. |
| C2 – Description of practices, policies, and future initiatives for transitioning towards a more sustainable economy | ||
| C2 | 48 | If you have put in place specific practices, policies or future initiatives for transitioning towards a more sustainable economy, which you have already reported under disclosure B2 in the Basic Module, you should briefly describe them. |
| C2 | 48 | If you answered YES to existing practices/ policies / future initiatives in disclosure B2, please choose the topic that they refer to. |
| C2 | 48 | If you answered YES to existing practices/ policies/ future initiatives in disclosure B2, please briefly describe them along with their consequent actions. (In case the practice/ policy/ future initiative covers suppliers or clients, you should mention it). |
| C2 | 48 | If you answered YES to future initiatives/ targets in disclosure B2, please specify them. |
| C2 | 49 | You may indicate the highest senior level in your organisation accountable for implementing them [if any]. |
| B3 – Energy and greenhouse gas emissions | ||
| B3 | 29 | Disclose your total energy consumption in MWh. |
| B3 | 29 | Renewable electricity |
| B3 | 29 | Non renewable electricity |
| B3 | 29 | Total electricity |
| B3 | 29 | Renewable fuels |
| B3 | 29 | Non-renewable fuels |
| B3 | 29 | Total fuels |
| B3 | 29 | Renewable self-generated electricity |
| B3 | 29 | Non-renewable self-generated electricity |
| B3 | 29 | Total self-generated electricity |
| B3 | 29 | Total energy consumption |
| B3 | 30a | Disclose your estimated Scope 1 GHG emissions in tCO2eq (from owned or controlled sources). |
| B3 | 30b | Disclose the location-based Scope 2 emissions in tCO2eq (i.e. emissions from the generation of purchased energy, such as electricity, heat, steam or cooling) |
| B3 | 30b | Disclose the market-based Scope 2 emissions in tCO2eq |
| B3 | 30b | Total Scope 1 and Scope 2 GHG emissions (location-based) |
| B3 | 30b | Total Scope 1 and Scope 2 GHG emissions (market-based) |
| B3 | 31 | Please disclose your GHG intensity calculated by dividing the gross greenhouse gas (GHG) emissions from Scope 1 and Scope 2 (location-based) by your turnover (in Euro). |
| B3 | 52 | Depending on the type of activities carried out by your organisation, disclose a quantification of your Scope 3 GHG emissions as appropriate. |
| B3 | 52 | 1 Purchased goods and services |
| B3 | 52 | Cloud computing and data centre services |
| B3 | 52 | 2 Capital goods |
| B3 | 52 | 3 Fuel and energy-related Activities (not included in Scope1 or Scope 2) |
| B3 | 52 | 4 Upstream transportation and distribution |
| B3 | 52 | 5 Waste generated in operations |
| B3 | 52 | 6 Business travel |
| B3 | 52 | 7 Employee commuting |
| B3 | 52 | 8 Upstream leased assets |
| B3 | 52 | 9 Downstream transportation |
| B3 | 52 | 10 Processing of sold products |
| B3 | 52 | 11 Use of sold products |
| B3 | 52 | 12 End-of-life treatment of sold products |
| B3 | 52 | 13 Downstream leased assets |
| B3 | 52 | 14 Franchises |
| B3 | 52 | 15 Investments |
| B3 | 52 | Total Scope 3 GHG emissions (tCO2eq) |
| B3 | 52 | Total Scope 1, Scope 2 and Scope 3 GHG emissions (location-based) |
| B3 | 52 | Total Scope 1, Scope 2 and Scope 3 GHG emissions (market-based) |
| C3 – GHG reduction targets and climate transition | ||
| C3 | 54 | If your organisation has established GHG emission reduction targets, please disclose your targets in absolute values for Scope 1 and Scope 2 emissions. In line with paragraphs 50 to 53 above and if you have set Scope 3 reduction targets, please also provide targets for significant Scope 3 emissions. |
| C3 | 54 | Descriptive target name |
| C3 | 54a | Target year |
| C3 | 54a | Target value |
| C3 | 54b | Base year |
| C3 | 54b | Base value |
| C3 | 54c | Unit used for the target |
| C3 | 54d | The share of Scope 1 emissions that the target concerns. |
| C3 | 54d | The share of Scope 2 emissions that the target concerns. |
| C3 | 54d | The share of Scope 3 emissions that the target concerns. |
| C3 | 54e | Please disclose a list of main actions you seek to implement to achieve the target. |
| C3 | 55 | If you operate in high climate impact sectors and have adopted a transition plan for climate change mitigation, please provide information about it, including an explanation of how you are contributing to reduce GHG emissions. |
| C3 | 56 | If you operate in high-climate impact sectors and do not have a transition plan for climate change mitigation in place, please indicate whether and, if so, when you will adopt such a transition plan. |
| C4 – Climate risks | ||
| C4 | 57a | If you have identified climate-related hazards and climate-related transition events,creating gross climate-related risks for your organisation, briefly describe them. |
| C4 | 57b | If you have identified climate-related hazards and climate-related transition events,creating gross climate-related risks for your organisation, disclose how you have assessed the exposure and sensitivity of your assets, activities and value chain to these hazards and transition events. |
| C4 | 57c | If you have identified climate-related hazards and climate-related transition events,creating gross climate-related risks for your organisation, disclose the time horizons of any climate-related hazards and transition events identified. |
| C4 | 57d | If you have identified climate-related hazards and climate-related transition events,creating gross climate-related risks for your organisation, disclose whether you have undertaken climate change adaptation actions for any climate-related hazards and transition events. |
| C4 | 58 | You may disclose the potential adverse effects of climate risks that may affect your financial performance or business operations in the short-, medium- or long-term, indicating whether you assess the risks to be high, medium, low. |
| B4 – Pollution of air, water, and soil | ||
| B4 | 32 | Are you required by law or other national regulations to report to competent authorities your emissions of pollutants, or if you voluntarily report on them according to an Environmental Management System, you should disclose the pollutants you emit to air, water and soil in your own operations, with the respective amount for each pollutant. If this information is already publicly available, you may alternatively refer to the document where it is reported, for example, by providing the relevant URL link or embedding a hyperlink. |
| B4 | 32 | Emissions to air |
| B4 | 32 | Pollutant |
| B4 | 32 | Mass |
| B4 | 32 | Emissions to water |
| B4 | 32 | Pollutant |
| B4 | 32 | Mass |
| B4 | 32 | Emissions to soil |
| B4 | 32 | Pollutant |
| B4 | 32 | Mass |
| B5 – Biodiversity | ||
| B5 | 33 | If your organization has identified sites in or near biodiversity sensitive areas that are negatively affected by its activities, please indicate the number of sites that are located in or near such areas that your organization owns, leases, or manages. |
| B5 | 33 | If your organization has identified sites in or near biodiversity sensitive areas that are negatively affected by its activities, please indicate the area of sites that are located in or near such areas that your organization owns, leases, or manages. |
| B5 | 34a | Please disclose your total use of land area. |
| B5 | 34b | Please disclose your total sealed area. |
| B5 | 34c | Please disclose your nature-oriented area on site. |
| B5 | 34d | Please disclose your nature-oriented area off site. |
| B6 – Water | ||
| B6 | 35 | Please disclose your total water withdrawal. |
| B6 | 35 | Please disclose the amount of water withdrawn at sites located in areas of high water-stress. |
| B6 | 35 | Site |
| B6 | 35 | Water withdrawn |
| B6 | 36 | If you have production processes in place which significantly consume water (e.g. thermal energy processes like drying or power production, production of goods, agricultural irrigation, etc.), please disclose the water consumption calculated as the difference between your water withdrawal and water discharge from your production processes |
| B6 | 36 | Total amount of water withdrawn |
| B6 | 36 | Water discharge from undertaking production processes |
| B6 | 36 | Total water consumption |
| B7 – Resource use, circular economy, and waste management | ||
| B7 | 37 | Please disclose whether you apply circular economy principles and, if so, how you apply these principles. |
| B7 | 38a | Please disclose the total annual generation of waste broken down by type (non-hazardous and hazardous). |
| B7 | 38a | Non-hazardous waste |
| B7 | 38a | Hazardous waste |
| B7 | 38a | Total waste |
| B7 | 38b | Please disclose the total annual waste diverted to recycling or reuse. You may also disclose the waste directed to disposal. |
| B7 | 38b | Waste diverted to recycle or reuse |
| B7 | 38b | Waste directed to disposal |
| B7 | 38b | Total waste |
| B7 | 38c | If you operate in a sector using significant material flows (for example manufacturing, construction, packaging or others), please disclose the annual mass-flow of relevant materials used. |
| B8 – Workforce – General characteristics | ||
| B8 | 39a | Please disclose the number of employees in headcount or full-time equivalent for type of employment contract (temporary or permanent). |
| B8 | 39a | Permanent |
| B8 | 39a | Temporary |
| B8 | 39b | Please disclose the number of employees in headcount or full-time equivalent for gender. |
| B8 | 39b | Male |
| B8 | 39b | Female |
| B8 | 39b | Other |
| B8 | 39b | Not reported |
| B8 | 39c | If your undertaking operates in more than one country, please disclose the number of employees in headcount or full-time equivalent for country of the employment contract. |
| B8 | 39c | Country |
| B8 | 39c | Number |
| B8 | 40 | If your undertaking employs 50 or more employees, please disclose your employee turnover rate for the reporting period. |
| B8 | 40 | Number of employees who left during the reporting period |
| B8 | 40 | Number of employees at the beginning of the reporting period |
| B8 | 40 | Number of employees at the end of the reporting period |
| B8 | 40 | Turnover rate |
| B9 – Workforce – Health and safety | ||
| B9 | 41a | Please disclose the number of recordable work-related accidents for your employees. |
| B9 | 41a | Please disclose the rate of recordable work-related accidents for your employees. |
| B9 | 41a | Number of hours worked by one full-time employee in the reporting period |
| B9 | 41a | Total number of hours worked in a year by all employees in the reporting period |
| B9 | 41a | Rate of recordable work-related accidents for your employees |
| B9 | 41b | Please disclose the number of fatalities as a result of work-related injuries and work-related ill health. |
| B10 – Workforce – Remuneration, collective bargaining, and training | ||
| B10 | 42a | Please disclose whether your employees receive pay that is equal or above applicable minimum wage for the country you report in, determined directly by the national minimum wage law or through a collective bargaining agreement. |
| B10 | 42b | If your company's headcount is above 150 employees (before 7 June 2031), or 100 employees (from 7 June 2031), please disclose the percentage pay gap between your female and male employees. |
| B10 | 42b | Average gross hourly pay level of male employees |
| B10 | 42b | Average gross hourly pay level of female employees |
| B10 | 42b | Pay gap |
| B10 | 42c | Please disclose the percentage of employees covered by collective bargaining agreements. |
| B10 | 42c | Number of employees covered by collective bargaining agreements |
| B10 | 42c | Number of employees |
| B10 | 42c | Percentage of employees covered by collective bargaining agreements |
| B10 | 42d | Please disclose the average number of annual training hours per employee, broken down by gender. |
| B10 | 42d | Male |
| B10 | 42d | Female |
| B10 | 42d | Other |
| B10 | 42d | Not reported |
| B10 | 42d | Average number of annual training hours per employee |
| C5 – Additional (general) workforce characteristics | ||
| C5 | 59 | If your organisation employs 50 or more employees, you may disclose the female-to-male ratio at management level for the reporting period. |
| C5 | 59 | Number of male employees at management level |
| C5 | 59 | Number of female employees at management level |
| C5 | 59 | Female-to-male ratio at management level |
| C5 | 60 | If your organisation employs 50 or more employees, you may disclose the number of those self-employed without personnel who are working exclusively for your undertaking. |
| C5 | 60 | If your organisation employs 50 or more employees, you may disclose the number of temporary workers provided by undertakings primarily engaged in ‘employment activities’. |
| C6 – Additional own workforce information - Human rights policies and processes | ||
| C6 | 61a | Do you have a code of conduct or human rights policy for your own workforce? |
| C6 | 61b | Does it cover child labor? |
| C6 | 61b | Does it cover forced labor? |
| C6 | 61b | Does it cover human trafficking? |
| C6 | 61b | Does it cover discrimination? |
| C6 | 61b | Does it cover accident prevention? |
| C6 | 61b | Does it cover any other specific topics? |
| C6 | 61c | Do you have a complaints-handling mechanism for your own workforce? |
| C7 – Severe negative human rights incidents | ||
| C7 | 62a | Does your organisation have confirmed incidents in your own workforce related to child labor? |
| C7 | 62a | Does your organisation have confirmed incidents in your own workforce related to forced labor? |
| C7 | 62a | Does your organisation have confirmed incidents in your own workforce related to human trafficking? |
| C7 | 62a | Does your organisation have confirmed incidents in your own workforce related to discrimination? |
| C7 | 62a | Does your organisation have confirmed incidents in your own workforce related to other topics? |
| C7 | 62a | If so, please describe what other incidents have occurred among the company's own workforce. |
| C7 | 62b | If there have been confirmed incidents in the company's own workforce related to the cases described in section 62a, you may describe the actions taken to resolve them. |
| C7 | 62c | Are you aware of any confirmed incidents involving workers in your value chain, affected communities, consumers and end-users? |
| C7 | 62c | If you are aware of any confirmed incidents involving workers in your value chain, affected communities, consumers and end-users, please specify them. |
| B11 – Convictions and fines for corruption and bribery | ||
| B11 | 43 | In case of convictions or fines for violations of anti-corruption and bribery laws during the reporting period, please indicate the number of convictions. |
| B11 | 43 | In case of convictions or fines for violations of anti-corruption and bribery legislation during the reporting period, please indicate the total amount of the fines. |
| C8 – Revenues from certain sectors and exclusion from EU reference benchmarks | ||
| C8 | 63a | If you are active in the controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons) sector, please disclose your related revenues in the sector. |
| C8 | 63b | If you are active in the cultivation and production of tobacco sector, please disclose your related revenues in the sector. |
| C8 | 63c | If you are active in the fossil fuel (coal, oil and gas) sector (i.e. the undertaking derives revenues from exploration, mining, extraction, production, processing, storage, refining or distribution, including transportation, storage and trade, of fossil fuels as defined in Article 2, point (62), of Regulation (EU) 2018/1999 of the European Parliament and the Council 17), including a disaggregation of revenues derived from coal, oil and gas sector, please disclose your related revenues in the sector. |
| C8 | 63c | Revenue derived from coal |
| C8 | 63c | Revenue derived from oil |
| C8 | 63c | Revenue derived from gas |
| C8 | 63c | Total revenues derived from fossil fuel |
| C8 | 63d | If you are active in the chemicals production (if you are a manufacturer of pesticides and other agrochemical products) sector, please disclose your related revenues in the sector. |
| C8 | 64 | Please disclose whether you are excluded from any EU reference benchmarks that are aligned with the Paris Agreement. |
| C9 – Gender diversity ratio in the governance body | ||
| C9 | 65 | If your organisation has a governance body in place, please disclose the related gender diversity ratio. |
| C9 | 65 | Number of female board members at the end of the reporting period |
| C9 | 65 | Number of male board members at the end of the reporting period |
| C9 | 65 | Gender diversity ratio in governance body |
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