assess record for 'disclosure of non-financial information ... · assess record for...

Assess record for 'Disclosure of Non-Financial Information by Companies'

Meta Informations Creation date 28-01-2011

Last update date

User name null

Case Number 362593624231702811

Invitation Ref.

Status N

Background Information For the purpose of analysis of this consultation you want to be identified as -single choice reply- (compulsory)

Preparer

If you are preparer, are you -single choice

reply- (compulsory)

Bank or other financial institutions

Please indicate your size: -single choice

reply- (compulsory)

Large

Are you listed on regulated market? -single choice reply- (compulsory)

Yes

In which country(ies) you are listed: -open reply- (compulsory)

DAX

Name(s) (of respondent and of your organisation / company) -open reply- (compulsory)

Allianz SE European Affairs Office

Country where your organisation / company is located -single choice reply-

(compulsory)

BE - Belgique / België

Please provide the name and location of parent company -open reply- (optional)

Allianz SE Munich, Germany

Your address -open reply- (optional)

Your e-mail address:

-open reply- (compulsory)

[email protected]

Short description of the general activity of your organisation / company: -open reply- (optional)

Is your organisation registered in the Interest Representative Register?

If your organisation is not registered, you have the opportunity to register here before you submit your contribution. Responses from organisations not registered will be published separately from the registered organisations. -single choice reply- (compulsory)

Yes

Please specify the Register ID number in the Interest Representative Register -

open reply- (compulsory)

05503341949-54

Can the Commission contact you if further details on the information you

Yes

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2/02/2011http://ec.europa.eu/yourvoice/ipm/forms/dispatch?userstate=View&id=3625936242317...

submitted is required? -single choice reply-

(compulsory)

Publication: Do you object to publication of the personal data on the grounds that such publication would harm your legitimate interests? -multiple

choices reply- (optional)

Questionnaire 1. How would you consider the current regime of disclosure of non-financial information applicable in your country? -single choice reply-

(compulsory)

Sufficient

Please explain

In replying to this question, please provide information on what way current reporting provides useful information, and to what extent it is sufficiently tailored to the circumstances of the company. Please also comment on whether you find non-financial information useful for the decision-making of a company. -open reply- (optional)

The German reporting regime (which in this matter is based on EU directives) requires companies to prepare a management report that, among others, has to provide a comprehensive analysis of the course of business and the position of the company. The analysis must include financial key performance indicators for the business activities and comment on them by reference to the amounts and disclosures presented in the financial statements. Also non-financial key performance indicators – for instance, information about environmental and employee matters – have to be disclosed, if they are essential for the understanding of the course of business and the position of the company. Thus, there is already an instrument for the disclosure of non-financial information. Although this instrument has no particular focus on sustainability information, any new regulation should take into account existing reporting obligations in order to avoid information overload, (costly) redundancies in the company’s reporting, and overlapping regulation.

2. Have you evaluated the effects, and costs and benefits, of any current corporate disclosure of environmental and social information? -single choice

reply- (compulsory)

Yes

Please explain -open reply- (optional)

Allianz published its first sustainable development report in 2002, which is the main communication channel for non-financial information to address the information requirements of certain stakeholders, such as rating agencies who use it to assess Allianz’ performance in the realm of sustainable development. At our headquarter in Munich, a central team has the responsibility for compiling this annual report in close cooperation with our global network. The preparation of the report involves significant personnel costs, costs for consultancy and communication, which are internally tracked. The benefits of reporting are greater transparency on our activities and reputation through recognition e.g. sustainability ratings, most of which base their analysis only on publicly available information. However, we acknowledge that this cost/benefit analysis may be different for other companies.

3. If you think that the current regime of disclosure of non-financial information should be improved, how do you suggest that this should be done?


We would welcome generally accepted standards for the reporting of CSR information. However, such standards have to be proportionate to the benefits resulting from such information for the various stakeholders and the additional cost imposed on companies. Such standards are most useful where they are accepted globally; however, they do not have to be mandatory. A CSR reporting based on recommendations should be considered.

4. In your opinion, should companies be required to disclose the following (check all relevant boxes): -multiple



We would welcome generally accepted, but voluntary, standards on the subjects laid out above. However, any new standards take into account already existing reporting requirements in order to avoid redundant reporting and, thereby also an information overload.

Principles

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5. In your opinion, for a EU measure on reporting of non-financial information to achieve materiality and comparability it should be based upon (check all relevant boxes): -multiple choices reply- (optional)

Key Performance Indicators (KPIs)

5a) In case you consider that Key Performance Indicators (KPIs) would be useful, would you think that they should be (check all relevant boxes): -multiple choices reply- (compulsory)

General for all economic sectors Sector specific

5b) Please indicate which indicators you would consider to be the most relevant for all economic sectors: -open reply- (optional)

As laid out above, we do not support a EU measure providing for mandatory, comprehensive CSR reporting requirements. However, if introduced, any new requirement should be proportionate to its use for the particular company and its stakeholders. However, we think that standards should ensure comparability and materiality of information disclosed. Existing developments, such as the GRI Sustainability Reporting Guidelines should be taken into account. They provide for a combination of general as well a sector-specific KPIs in order to: 1. ensure a certain degree of comparability across industries, 2. take into account sector specifics and differences across industries.

6. In your opinion, what should be the process to identify relevant principles and/or indicators (whether general or sector-specific)?

Please explain

In replying to this question, please comment on whether the Commission should endorse or make reference to any existing international frameworks (or a part of them), such as Global Reporting Initiative (GRI), UN Global Compact, the OECD Guidelines, ISO 26000, or other frameworks; or whether companies should be required to select relevant indicators together with their investors and other stakeholders and to disclose information according to such indicators, depending on the use that different stakeholders would make of such information. -open reply- (optional)

Existing standards, such as the CRI Reporting Guidelines, should be used as a basis. What is required is a globally accepted reporting framework. It will not be sufficient to only establish a European framework (strong European/US interaction).

7. In your opinion, should companies be required to disclose the steps they take to fulfill the corporate responsibility to respect human rights? -single choice reply- (compulsory)

No


We appreciate the current developments towards an increasing CSR reporting absent a respective regulatory environment. We could imagine (voluntary) reporting standards including disclosure of the steps to fulfil the corporate responsibility to respect human rights is reasonable, but any such reporting standards should respect the nature of the business and take into account the specific risk exposure of industries.

8. In your opinion, should companies be required to disclose the risks they face and the policies they have in the field of corruption and bribery? -single

choice reply- (compulsory)

No


Current requirements on risk reporting do (at least partly) cover this issue, where relevant for the particular company. Where not relevant, we would not see any benefit in the disclose of policies. Again, any (voluntary) reporting standards on this matter would be reasonable.

9. In your opinion, what companies should be required to disclose non-financial information (check only one box)? -single choice reply- (compulsory)

None

10. In your opinion, should institutional investors be subject to specific or additional disclosure requirements, for example to

No

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disclose whether and how they take into account environmental and social issues in their investment decisions? -single choice reply- (compulsory)

Please explain

In replying to this question, please provide information on which issues seem to be the most relevant and why; and which institutional investors should be subject to such an obligation. -open reply- (optional)

In our opinion, there should be no disclosure requirement for institutional investors. In the interest of increased transparency, reporting on investment criteria would be good practice in the interest of their stakeholders.

11. In your opinion, should European policy promote the concept of "integrated reporting"?

Integrated reporting refers to a report that integrates the company's key financial and non-financial information to show the relationship between financial and non-financial performance (environmental, social, and governance). -single choice reply- (compulsory)

Yes

Please explain

In replying to this question, please indicate the advantages and disadvantages of an integrated report, as well as possible specific costs of integrated reporting. -open reply- (optional)

We believe that only an integrated reporting can address the problems of information overload, reporting redundancies, and increasing, sometimes even conflicting, reporting requirements. However, integrated reporting should not lead to additional complexity. The concept of integrated reporting increasingly climbs the agenda of reporting professionals, there are a number of advantages attached to publishing one report on the company’s financial and non-financial information: 1. integrated reporting demonstrates that sustainability is a key component of a company’s business, 2. it enhances transparency on the interrelation of a company’s financial and non-financial performance, 3. facilitates integration into mainstream financial analysis, 4. gives holistic view about a company’s activities.

12. In your opinion, should disclosed non-financial information be audited by external auditors? -single choice reply-

(compulsory)

No

Please explain

In replying to this question please provide any evidence you may have regarding costs of auditing non-financial information, as well as your views on other possible forms of independent reviews besides external auditing. -open reply- (optional)

We do not see any benefit in an audit requirement which could in the least the considerable cost caused by it. The quality of such an audit would necessarily be doubtful, as ,compared to financial data, where strict guidelines on how to collect and process data exist making it auditable, for non-financial data these standards and processes are still in their infancy and as such would are be auditable at this point in time..

13. If you have relevant documents you want to share with us, please attach them here. (optional) -multiple


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