Shift welcomes the publication of the first draft set of European Sustainability Reporting Standards and commends the European Financial Reporting Advisory Group on producing a rich and important set of draft standards in a short period of time. While we are responding separately to a number of the survey questions circulated as part of the consultation process, we recognize that these do not allow for the full expression of views on the draft standards and therefore submit this letter also to complement our survey responses. In it we address issues related to:
- The architecture of the cross-cutting standards
- The articulation of the materiality assessment process
- Providing clarity on the central role of due diligence
- Focusing on the materiality process rather than ‘rebuttable presumptions’.
- Alignment with international standards and the definition of value chains
- The relevance of governance and business models to information on due diligence
- Relevance of governance disclosures to alignment with due diligence standards
- Relevance of business models as source of impacts in the context of due diligence
- The significance of engagement with affected stakeholders
- Value of clearly distinguishing affected stakeholders and their particular relevance
- Need for cross-cutting disclosures on engagement with affected stakeholders
- The value of the architecture of the social standards
- Value of division into standards based on stakeholder group
- Need for performance metrics for all stakeholder groups in future standards
