Top Improvement Actions
1
HIGH PRIORITY
E1-6
Improve Gross Scope 2 GHG Emissions (E1-6). Missing: Market-based Scope 2 GHG emissions, Location-based Scope 2 GHG emissions, Methodology for Scope 2 emissions calculation
2
HIGH PRIORITY
E1-6
Improve GHG Emissions Intensity (E1-6). Missing: ratio value, denominator definition
3
HIGH PRIORITY
E1-4
Improve Climate Targets (E1-4). Missing: Baseline year, Target year, Reduction percentage
4
HIGH PRIORITY
E1-5
Improve Energy Consumption and Mix (E1-5). Missing: total consumption MWh or GJ, renewable share %, non-renewable share %
5
HIGH PRIORITY
E1-1
Improve Transition Plan for Climate Change Mitigation (E1-1). Missing: key actions list, timelines per action, investment/capex amounts
Greenwashing Risk Signals
Gross Scope 1 GHG Emissions - Missing baseline year for a target
Gross Scope 2 GHG Emissions - Missing baseline year for a target
Gross Scope 2 GHG Emissions - Missing methodology for emissions calculation
Gross Scope 2 GHG Emissions - Scope 3 total disclosed but categories not enumerated
Gross Scope 3 GHG Emissions - Missing baseline year for a target
GHG Emissions Intensity - Vague commitment without numbers
GHG Emissions Intensity - Missing baseline year for a target
Climate Targets - Missing baseline year for a target
Disclosure Detail
0 of 0
Environment
Weight = contribution to overall score (higher = more impact).
| Section | Disclosure | Status | Weight |
|---|---|---|---|
| E1-6 MANDATORY |
Gross Scope 1 GHG Emissions
Rationale The report includes the absolute value of Scope 1 emissions in tCO2e and mentions the GHG Protocol methodology. Evidence "Scope 1 GHG emissions amounted to 44,405 tCO₂e in the reporting year (2024: 76,989 tCO₂e)." Missing baseline year for a target
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points consolidation approach GRI cross-reference GRI GRI 305-1 full Omnibus note Retained as mandatory : Scope 1 is a core climate metric under all regimes. |
✓ FOUND High confidence | 8 |
| E1-6 MANDATORY |
Gross Scope 2 GHG Emissions
Rationale The report mentions Scope 2 emissions but lacks specific market-based and location-based values and methodology. Evidence "There were no significant Scope 1 and Scope 2 GHG emissions outside the Company E financial consolidated group in the reporting year." Missing baseline year for a targetMissing methodology for emissions calculationScope 3 total disclosed but categories not enumerated
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points Market-based Scope 2 GHG emissions, Location-based Scope 2 GHG emissions, Methodology for Scope 2 emissions calculation GRI cross-reference GRI GRI 305-2 full Omnibus note Retained. Simplified ESRS still requires both market-based and location-based. |
⚠ PARTIAL Medium confidence | 8 |
| E1-6 MANDATORY |
Gross Scope 3 GHG Emissions
Rationale The report includes specific Scope 3 GHG emissions figures and methodology documentation, meeting disclosure requirements. Evidence "Total gross indirect (Scope 3) GHG emissions (2024 without BYR: 19,981,165 tCO2e)" Missing baseline year for a target
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points Baseline year for the Scope 3 emissions GRI cross-reference GRI GRI 305-3 partial Omnibus note Retained but simplified : companies may now report only significant Scope 3 categories rather than all 15, provided they justify exclusions. |
✓ FOUND High confidence | 10 |
| E1-6 MANDATORY |
GHG Emissions Intensity
Rationale The report mentions methods and assumptions for Scope 3 emissions but does not provide specific data on GHG emissions intensity. Evidence "The methods and assumptions used to calculate Scope 3 emissions are documented in an internal manual and updated annually." Vague commitment without numbersMissing baseline year for a target
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points ratio value, denominator definition GRI cross-reference GRI GRI 305-4 full Omnibus note Moved to voluntary under the Omnibus simplification : intensity ratios are no longer mandatory but remain best practice. |
⚠ PARTIAL Medium confidence | 5 |
| E1-4 MANDATORY |
Climate Targets
Rationale The report mentions climate targets and Scope 3 emissions but lacks specific reduction targets with baseline and target years. Evidence "The methods and assumptions used to calculate Scope 3 emissions are documented in an internal manual and updated annually." Missing baseline year for a targetMissing methodology for emissions calculation
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points Baseline year, Target year, Reduction percentage, Scope coverage of target, SBTi validation status GRI cross-reference GRI GRI 305-5 partial Omnibus note Retained as mandatory. However, Omnibus removed the requirement to align targets with EU Climate Law pathways : companies now set their own trajectories. |
⚠ PARTIAL Medium confidence | 8 |
| E1-5 MANDATORY |
Energy Consumption and Mix
Rationale The passage mentions energy factors but does not provide the required breakdown of energy consumption by source type and intensity ratio. Evidence "No different reporting periods have to be taken into account." Missing baseline year for a target
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points total consumption MWh or GJ, renewable share %, non-renewable share %, energy intensity ratio GRI cross-reference GRI GRI 302-1, GRI 302-3, GRI 302-4 full GRI stricter: GRI 302-1 requires energy breakdown by fuel type and by renewable/non-renewable per source. ESRS E1-5 allows aggregated totals : GRI is more granular here. Omnibus note Retained. Renewable share and total consumption remain mandatory. |
⚠ PARTIAL Medium confidence | 6 |
| E1-1 MANDATORY |
Transition Plan for Climate Change Mitigation
Rationale The passage mentions a transition plan but lacks specific actions with timelines and investment/capex amounts. Evidence "The Company E Group devised a transition plan based on the existing decarbonization approach of its Sustainability strategy." Vague commitment without numbers
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points key actions list, timelines per action, investment/capex amounts, Paris alignment statement GRI cross-reference GRI GRI 201-2 partial Omnibus note Significantly relaxed under Omnibus. Transition plans are now voluntary for most companies; only financial sector entities face stricter requirements. |
⚠ PARTIAL Medium confidence | 6 |
| E2-4 |
Emissions to Air, Water and Soil
Rationale The passage discusses water use and reduction of environmental impact but does not provide specific pollutant emissions data as required by E2-4. Evidence "Water use in the upstream value chain... The Company E Group records the use of water resources as part of overarching environmental indicators." Non-material (explicit) (p.106) - "relevant internal experts. With the **→ Site-based environmental strategy**, Company E and selected group companies aim to reduce water withdrawal, water consumption, the amount of water discharged and emissions into wastewater at all Pors"
DetailsMissing data points pollutant type, emission medium (air/water/soil), absolute quantity GRI cross-reference GRI GRI 305-7 partial GRI stricter: GRI 305-7 requires NOx, SOx and other air emissions by weight. ESRS E2-4 covers air, water and soil but GRI 305-7 requires a more specific pollutant-by-pollutant breakdown. Omnibus note Remains subject to materiality assessment. Mandatory only if pollution is identified as a material topic. |
⚠ PARTIAL Medium confidence | 4 |
| E3-4 |
Water Consumption
Rationale The report provides specific figures for water consumption in high water stress areas, along with methodology details. Evidence "Water consumption in areas with high water stress amounted to 160,201 m³ in the reporting year (2024: 25,362 m³)." Missing baseline year for a target
Non-material (explicit) (p.159) - "- **Not material** Combined Management Report with **Non-Financial Statement** Annex 315 ESRS E1-7 GHG removals and carbon credits paragraph 56 Regulation (EU) 2021/1119, Article 2(1) ESRS E1-9 Exposure of the benchmark portfolio to clima"
DetailsMissing data points Total water withdrawal, Water sources (surface/ground/municipal), Recycled water % GRI cross-reference GRI GRI 303-3, GRI 303-4, GRI 303-5 partial GRI stricter: GRI 303-3 requires breakdown of water withdrawal by source (surface water, groundwater, seawater, produced water, third-party water). ESRS E3-4 does not require this source-level granularity : GRI is stricter here. Omnibus note Remains subject to materiality. Mandatory only if water is material : e.g., manufacturing, food & beverage, semiconductors. |
✓ FOUND High confidence | 4 |
| E4-1 |
Biodiversity and Ecosystem Policies
Rationale The report mentions an assessment of biodiversity-sensitive areas but lacks specific policies, metrics, or action plans related to biodiversity and ecosystems. Evidence "The Company E Group has not identified any sites that are located in or close to biodiversity-sensitive areas that are negatively impacted." Vague commitment without numbers
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points Policies and transition plans related to biodiversity conservation, Biodiversity metrics or targets GRI cross-reference GRI GRI 304-1, GRI 304-2, GRI 304-3, GRI 304-4 partial GRI stricter: GRI 304-1 requires the size of each operational site in or near protected areas. ESRS E4 allows aggregated figures. GRI 304-4 requires a count of IUCN Red List species affected : ESRS has no equivalent requirement. Omnibus note Moved to fully voluntary for most sectors under Omnibus. Remains mandatory only for companies with significant land-use impacts. |
⚠ PARTIAL Medium confidence | 3 |
| E5-5 |
Resource Use and Waste
Rationale The passage mentions waste management and circular economy goals but lacks specific quantitative data on total waste generated, hazardous vs non-hazardous waste, recycling rates, or disposal method breakdowns. Evidence "The Company E Group is working to continuously increase its use of secondary materials and renewable raw materials and, in doing so, preserve resources." Vague commitment without numbers
Non-material (explicit) (p.159) - "of Annex 1 - p. 211 – 212 ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24 (b) Indicator number 11 Table #2 of Annex 1 ESRS E4-2 Sustainable oceans / seas practices or policies paragraph 24 (c) Indicator number "
DetailsMissing data points total waste metric tons, hazardous waste %, recycling/reuse rate, disposal method breakdown GRI cross-reference GRI GRI 306-3, GRI 306-4, GRI 306-5 full GRI stricter: GRI 306-3 requires waste disclosed by hazardous / non-hazardous AND by disposal method (landfill, incineration, recycling, etc.) simultaneously. ESRS E5-5 allows these to be reported separately : GRI requires the cross-tabulation. Omnibus note Subject to materiality. Mandatory if resource use is identified as material. |
⚠ PARTIAL Medium confidence | 4 |
Social
Weight = contribution to overall score (higher = more impact).
| Section | Disclosure | Status | Weight |
|---|---|---|---|
| S1-9 MANDATORY |
Diversity and Equal Opportunities
Rationale The report mentions gender quotas and targets but lacks overall gender distribution and pay gap data. Evidence "In the reporting year, the statutory gender quota came to 29.1% (2024: 22%) at the first management level and 18.7% (2024: 18.8%) at the second management level, thus meeting the targets set for 2025." Vague commitment without numbers
Non-material (explicit) (p.157) - "p. 209 ESRS E5-5, p. 226 – 228 **List of datapoints in cross-cutting and topical standards that derive from other EU legislation** **Material/** **Paragraph or** **Disclosure requirement and related datapoint** **SFDR reference** **Pillar 3"
DetailsMissing data points % female employees total, % female in management overall, % female on board, gender pay gap % GRI cross-reference GRI GRI 405-1 partial GRI stricter: GRI 405-1 requires diversity breakdown by employee category (board, sCompany Cor management, middle management, employees). ESRS S1-9 requires board and total employees but not the full category ladder : GRI is more granular. Omnibus note Retained. Gender diversity metrics remain mandatory under simplified ESRS. |
⚠ PARTIAL Medium confidence | 5 |
| S1-14 MANDATORY |
Health and Safety
Rationale The report mentions health and safety targets but lacks specific numerical data points such as LTIFR or fatality counts. Evidence "Company E Group has drafted a conceptual target for occupational health and safety that is enshrined in its occupational health and safety policy" Vague commitment without numbers
Non-material (explicit) (p.157) - "p. 209 ESRS E5-5, p. 226 – 228 **List of datapoints in cross-cutting and topical standards that derive from other EU legislation** **Material/** **Paragraph or** **Disclosure requirement and related datapoint** **SFDR reference** **Pillar 3"
DetailsMissing data points fatality count, LTIFR value, recordable injury rate, ill health cases, coverage scope GRI cross-reference GRI GRI 403-9, GRI 403-10 partial GRI stricter: GRI 403-9 covers employees AND workers not employed by the organisation whose work is controlled by the company. ESRS S1-14 covers a narrower scope of non-employee workers : GRI is broader here. Omnibus note Retained. LTIFR and fatalities remain mandatory. |
⚠ PARTIAL Medium confidence | 5 |
| S1-13 MANDATORY |
Training and Skills Development
Rationale The report provides specific numbers for average training hours per employee, and breaks down by employee category. Evidence "The average number of training hours per employee was 19.7 hours (2024: 21.0 hours)." Non-material (explicit) (p.157) - "p. 209 ESRS E5-5, p. 226 – 228 **List of datapoints in cross-cutting and topical standards that derive from other EU legislation** **Material/** **Paragraph or** **Disclosure requirement and related datapoint** **SFDR reference** **Pillar 3"
DetailsGRI cross-reference GRI GRI 404-1 full Omnibus note Moved to voluntary under Omnibus simplification : training hours are no longer a mandatory disclosure. |
✓ FOUND High confidence | 4 |
| S1-8 MANDATORY |
Collective Bargaining Coverage
Rationale The report provides a clear percentage of employees covered by collective bargaining agreements and additional relevant details. Evidence "In the reporting year, 76.5% of all employees in the Company E Group were covered by collective bargaining agreements (2024: 76.8%)" Non-material (explicit) (p.157) - "p. 209 ESRS E5-5, p. 226 – 228 **List of datapoints in cross-cutting and topical standards that derive from other EU legislation** **Material/** **Paragraph or** **Disclosure requirement and related datapoint** **SFDR reference** **Pillar 3"
DetailsGRI cross-reference GRI GRI 402-1, GRI 407-1 partial Omnibus note Retained as mandatory. |
✓ FOUND High confidence | 4 |
| S2-1 |
Value Chain Workers : Due Diligence
Rationale The passage mentions due diligence measures and responsible sourcing but lacks a comprehensive description of the due diligence process and remediation mechanism. Evidence "Company E is also an active member of the Responsible Mica Initiative." Vague commitment without numbers
Non-material (explicit) (p.199) - "0 - - 0 **0** Newly extended/purchased financial assets (additions) 98 - - 8 **106** Other changes within a stage 0 - 0 - **0** Transfers to Stage 1 7 –4 –3 - **–** Stage 2 –43 43 - - **–** Stage 3 –53 - 53 - **–** Financial instruments der"
DetailsMissing data points Human rights policy, Supplier code of conduct, Due diligence process description, Remediation mechanism GRI cross-reference GRI GRI 408-1, GRI 409-1, GRI 414-1 partial GRI stricter: GRI 408-1 (child labour) and GRI 409-1 (forced labour) require identification of specific operations and suppliers at significant risk. ESRS S2-1 requires policies and due diligence process : GRI demands more operational specificity. Omnibus note Remains subject to materiality. Note: CSDDD (CS3D) companion directive also addresses supply chain due diligence obligations separately. |
⚠ PARTIAL Medium confidence | 4 |
Governance
Weight = contribution to overall score (higher = more impact).
| Section | Disclosure | Status | Weight |
|---|---|---|---|
| G1-1 MANDATORY |
Governance Structure and ESG Oversight
Rationale The report includes details on the integration of ESG targets into executive remuneration, the existence of an ESG committee, and the governance structure. Evidence "Since 2023, ESG targets have also been firmly anchored in the remuneration system for the management of Company E and selected national group companies." ESG targets in remuneration not quantified
Non-material (explicit) (p.199) - "0 - - 0 **0** Newly extended/purchased financial assets (additions) 98 - - 8 **106** Other changes within a stage 0 - 0 - **0** Transfers to Stage 1 7 –4 –3 - **–** Stage 2 –43 43 - - **–** Stage 3 –53 - 53 - **–** Financial instruments der"
DetailsMissing data points Specific composition of the ESG committee, Detailed description of board composition GRI cross-reference GRI GRI 2-9, GRI 2-10, GRI 2-11 full Omnibus note Retained. Governance structure disclosure remains a core requirement. |
✓ FOUND High confidence | 5 |
| G1-3 MANDATORY |
Anti-Corruption and Anti-Bribery
Rationale The report includes specific data on training coverage percentages and mentions anti-corruption policies and whistleblower protection. Evidence "In the reporting year 2025, the share of trained indirect employees at companies with increased risk was 82.4%" Non-material (explicit) (p.199) - "0 - - 0 **0** Newly extended/purchased financial assets (additions) 98 - - 8 **106** Other changes within a stage 0 - 0 - **0** Transfers to Stage 1 7 –4 –3 - **–** Stage 2 –43 43 - - **–** Stage 3 –53 - 53 - **–** Financial instruments der"
DetailsGRI cross-reference GRI GRI 205-2 full GRI stricter: GRI 205-2 requires % of governance body members AND employees trained on anti-corruption policies, broken down by region. ESRS G1-3 requires training coverage % but does not mandate regional breakdown. Omnibus note Retained. Anti-corruption remains a core governance disclosure. |
✓ FOUND High confidence | 6 |
| G1-4 MANDATORY |
Confirmed Corruption and Bribery Incidents
Rationale The report explicitly states there were no confirmed corruption or bribery incidents, fines, or legal proceedings. Evidence "As in the prior year, there were no known matters that led to convictions for violations of anti-corruption and anti-bribery laws or any fines within the Company E Group in the reporting year." Non-material (explicit) (p.199) - "0 - - 0 **0** Newly extended/purchased financial assets (additions) 98 - - 8 **106** Other changes within a stage 0 - 0 - **0** Transfers to Stage 1 7 –4 –3 - **–** Stage 2 –43 43 - - **–** Stage 3 –53 - 53 - **–** Financial instruments der"
DetailsGRI cross-reference GRI GRI 205-3 full Omnibus note Retained. |
✓ FOUND High confidence | 4 |
| G1-5 |
Political Influence and Lobbying
Rationale The report mentions lobbying activities and a policy but lacks specific financial contribution amounts or detailed lobbying expenditures. Evidence "The Company E Group has not formulated a measurable, outcome-oriented and time-bound target within the meaning of the ESRS" Vague commitment without numbers
Non-material (explicit) (p.199) - "0 - - 0 **0** Newly extended/purchased financial assets (additions) 98 - - 8 **106** Other changes within a stage 0 - 0 - **0** Transfers to Stage 1 7 –4 –3 - **–** Stage 2 –43 43 - - **–** Stage 3 –53 - 53 - **–** Financial instruments der"
DetailsMissing data points total financial contributions, lobbying topics, trade associations and their ESG positions GRI cross-reference GRI GRI 415-1 full Omnibus note Subject to materiality. Voluntary under Omnibus for most companies. |
⚠ PARTIAL Medium confidence | 3 |