About this question 

A diverse board of directors or senior leaders will include a variety of perspectives, skills, ages, genders, cultures, and ethnicities in order to perform its obligations effectively. Evidence shows that having a diverse board/senior management is essential for effective decision-making, guidance and governance. Targets and indicators are critical elements of driving effective practice within a company. This question asks to see if your company has a structured approach to increasing and maintaining board/management diversity across a range of characteristics.

• Answer yes if you can provide evidence that your company has set targets to increase board diversity for two or more characteristics (e.g., gender and national origin). ‘Yes’ can be scored if you can provide evidence of a diverse board and a stated commitment to maintain or improve these levels
• Answer no if you have no formal targets related to board/senior management diversity

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_MQ

Evidence

Either

• Link to published board/senior leadership diversity targets (e.g ESG strategy or report, DEI report, corporate website, Annual Report and Accounts)

or

• Internal strategy or program documentation indicating board/senior leadership diversity targets

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, HR or Corporate Governance report by senior leader, Board papers)

Topic areas

Board composition

About this question 

Having a diverse board/senior management is essential for effective decision-making, guidance and governance. Some regulatory authorities have introduced mandatory gender balance requirements and reporting.  This question assumes your company is already compliant with the law and asks whether your company has gender equality targets at board level that exceed regulatory requirements in your region.

• Answer yes if you can provide evidence that your company has formal gender equality targets that exceed regulatory requirements. If there are no such requirements in your company’s region, you can answer yes if your company has a board level gender equality target in place
• Answer no if there is no board/senior management gender equality target in place that goes beyond the regulatory requirements in your company’s region

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_Mg

Evidence

Either

• Link to published board/senior leadership gender equality targets (e.g., ESG strategy or report, DEI report, corporate website, Annual Report and Accounts)

and

• Link to evidence setting out the regulatory requirement relating to board gender equality targets in the relevant region for your company (to enable the verifier to see whether your company’s targets meet or exceed regulatory requirement)

or

• Internal strategy or program documentation indicating board/senior leadership gender equality targets

and

• Link to evidence setting out the regulatory requirement relating to board gender equality targets in the relevant region for your company (to enable the verifier to see whether your company’s targets meet or exceed regulatory requirement)

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, HR or Corporate Governance report by senior leader, Board papers)

Topic areas

Board composition

About this question 

Diverse management is essential for a company’s success in today’s globalized and interconnected world. A diverse management team promotes an inclusive workplace culture, improving employee morale, satisfaction, and retention. It also helps in understanding and connecting with a diverse customer base, leading to increased revenue.

This question looks for evidence of a structured approach and activities aimed at achieving its board/senior management diversity targets (e.g., examples could include mentorship programs for under-represented groups, targeted recruitment campaigns, changes in recruitment practice).

• Answer yes if you can provide evidence of your company’s strategy to increase diversity at board/senior management level. Examples could include HR strategy, board minutes, annual reports
• Answer no if there is no program or strategy in place to achieve your senior level diversity targets

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_Mw

Evidence

Either

• Link to published strategy or implementation program intended to deliver board diversity targets (e.g., description in Annual Report and accounts, HR section of corporate website, feature on recruitment website)

or

• Internal board diversity strategy/ implementation program documentation (HR strategy or report, documented information about a range of activities to increase diversity)

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, HR Report presented to board or senior leadership, board papers)

Optional supplementary evidence:

• Examples/screenshots of evidence of program implementation (e.g., leadership sponsorship and mentoring programs, coaching, pro-active recruitment processes/job adverts)

Topic areas

Board composition

About this question 

By fostering a gender-balanced leadership team, businesses can tap into a wealth of diverse perspectives, experiences, and skills. This diversity enables companies to make better decisions, drive innovation, and enhance employee engagement. This question asks if your company is monitoring and reporting on the distribution of genders at top management level. This should include reporting by both number and percentage.

This question is asking whether your company is tracking diversity data and achieving its own targets for increasing board/senior management diversity. Please note that the term ‘most recent’ has been considered as ‘annual’ but may not be appropriate in all cases.

• Answer yes if you can provide evidence that 100% of your company annual milestone targets on board diversity have been fully met

• Answer partial yes if you can provide evidence that at least 50% of your company annual milestone targets have been fully met

• Answer no if less than 50% of your company annual milestone targets have been fully met or if board diversity data is not available

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_NA

Evidence

Either

• Link to published report or update demonstrating progress against board/senior leadership diversity targets and milestones (e.g., ESG report, HR Report, Annual Report and Accounts, progress update on corporate website, DEI report)

or

• Internal progress report with oversight by senior management (e.g., Board ESG Committee papers, HR report to leadership)

or

• Reports on your company’s progress from third party assessment frameworks, NGO or benchmarking organizations

and

• Internal evidence that connects the issues addressed by the benchmarking framework(s) chosen with your company’s priority areas for development (e.g., disability, LGBTQ+, national origin, age)

Topic areas

Board composition

About this question 

ESG objectives need to be integrated into the overall strategy of a company to ensure potential conflicts with other strategic targets—such as financial goals—are identified and resolved. To embed ESG into a company’s strategy effectively, it is crucial for senior management to develop a strong understanding of environmental, social, and governance (ESG) issues. This question seeks evidence of ESG capacity buildinG at the senior level. If your company has a board of directors, the response should refer to this group. If there is no board of directors, it should refer to the most senior decision-making executives, identified in the BRM as “senior management” or “leadership.”

Capacity building may involve appointing individuals with ESG expertise to the board/senior management team, creating ESG-specific roles within leadership, or conducting regular training and development activities on key ESG topics for board/leadership team members. The question specifically refers to activities conducted during the reporting year.

Learning and development initiatives should comprehensively address all aspects of ESG and business conduct, including governance topics such as bribery, corruption, and data privacy. Training should be tailored to the needs of senior leadership and delivered by experts in the relevant field. Training providers may include internal ESG specialists, external training organizations, online learning tools, industry speakers, NGOs, policy advisors, academics, or other competent professionals.

• Answer yes if you can provide evidence of board/leadership team capacity building in all three areas of ESG, individually and as a group
• Answer partial yes if you can provide evidence of either individual or group capacity building in one or more areas of ESG
• Answer no if there is no evidence that the board /senior management team is building its knowledge and capacity in ESG issues

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_NQ

Evidence

Provide

• An internal Learning & Development (L&D) roadmap or strategic plan indicating how senior leaders/board members are undertaking sufficient development to keep abreast of ESG issues.

and

• A completed ESG learning needs assessment for board members/senior leadership on material issues for the business, aligned with the ESG risk assessment.

and

• Evidence of training, learning, or capacity-building activity for board/senior leadership undertaken during the reporting period (e.g., training log).

• Evidence of plans to strengthen ESG capacity across the leadership team, including recruitment plans and job descriptions for new senior posts.

Optional supplementary evidence:

• Examples/screenshots of ESG training materials learning experiences provided to board members/senior leaders
• Feedback from board members/senior leaders following successful learning event

Topic areas

Board accountability

About this question 

The board/senior leadership team of a company are ultimately accountable for the long-term sustainability of the business. As ESG factors can have a significant impact on a company’s long-term sustainability, financial performance, and reputation, the board has a fiduciary duty to ensure that the company is managing these risks and opportunities effectively. This includes setting ESG targets, monitoring progress, and ensuring that the company is complying with applicable laws and regulations.

This question asks if your company’s ESG strategies and targets are subject to oversight at the highest level of the company, either by a Board of directors, or senior management, whichever is the most senior decision making body applicable.

Examples of board oversight include, setting/approval of targets and strategy, regular monitoring of progress against targets, embedding ESG into across other business strategy and functions (e.g., investment strategy, performance management).

• Answer yes if you can provide evidence that ESG is subject to oversight at the highest level within the company
• Answer no if ESG is not subject to oversight at the highest level within the company

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_Ng

Evidence

Provide

• Internal documentation demonstrating how the board/senior leadership of your company oversees the setting of targets, and monitors and tracks progress in ESG (e.g., board or senior management meeting minutes, agendas, committee papers, reports)

and

• Internal documentation demonstrating how ESG topics are embedded across business functions (e.g., responsible investment policies, ESG workstream in learning and development, sprint groups or cross-business working parties on critical ESG issues)

Topic areas

Board accountability

About this question 

ESG due diligence policies help a company identify and manage potential risks and opportunities related to ESG. They can ensure that a company complies with applicable laws and regulations, and promotes transparency and accountability. Aside from looking at all the relevant risk factors for a company, the policy should establish metrics and reporting mechanisms to track progress and communicate ESG performance to stakeholders.

• Answer yes if you can provide evidence that your company’s board/senior management have implemented appropriate mechanisms to track environmental, social and governance targets
• Answer partial yes if your company’s evidence relates to just one or two pillars and not the full remit of ESG, or if metrics and targets are not set in all areas
• Answer no if there is no evidence of a top-down approach to allocating resource and appropriate mechanisms to implement ESG in your company

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_Nw

Evidence

Provide

• Internal strategic documentation explaining due diligence system: responsible persons, scope and approach

and

• Detail of the mechanisms used to track environmental, social and governance targets (e.g., databases, board or senior management meeting minutes, agendas, committee papers, reports)

and

• Evidence of oversight by board/senior leadership (e.g., ESG Committee minutes, Board papers)

Optional supplementary evidence

• Examples/screenshots of ESG tracking systems

Topic areas

Performance and incentives

About this question 

ESG objectives need to be integrated into the overall strategy of a company to ensure conflicts with other strategic targets – such as financial goals – are identified and resolved. Linking executive compensation to environmental, social, and governance (ESG) performance has been shown as one way to help drive accountability and progress on the ESG agenda.

This question is about executive incentives. It asks whether your company has established a mechanism by which company or individual achievement of ESG targets and goals is linked to salary, bonus, share options or other reward and compensation schemes for Board and/or senior management.

• Answer yes if you can provide evidence that your company’s board/senior management incentives and reward mechanisms include the requirement for individual and/or company achievement of ESG targets.  We are looking for the whole of the senior management team to have ESG performance metrics in place
• Answer partial yes if your company’s evidence relates to just one or two of the three pillars of ESG, or if a proportion of the senior team have ESG performance metrics in place related to reward
• Answer no if there is no direct link between ESG targets and executive reward in your company

CSRD:

Listed companies should provide information disclosed to shareholders related to incentive schemes. Companies should prepare to disclose:

1. a description of the key characteristics of the incentive schemes;
2. whether performance is assessed against specific sustainability-related targets and/or impacts, and if so, which ones;
3. whether and how sustainability-related performance metrics are included in remuneration policies or considered as performance benchmarks;
4. the proportion of variable remuneration tied to sustainability-related targets and/or impacts; and
5. the level within the organization at which the terms of incentive schemes are approved and updated.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_OA

Evidence

Either

• Link to published information on how compensation for senior leaders/board members is linked to achievement of ESG goals (e.g., Annual Report and Accounts,  Corporate Governance Report, Compensation and Benefits Report)

or

• Internal HR policies and Board/leadership reward process documentation that sets out out how board level bonuses or compensation incentives are linked to achievement of ESG targets (e.g.,, payment of board member/leadership bonus dependent or partially dependent on the company achieving net zero targets or milestones, and/or each leader’s personal targets related to ESG goals)

Note: Evidence can include board minutes or reports, HR, reward or compensation policies, audit committee paperwork

Topic areas

Performance and incentives

About this question 

Successfully delivering a robust ESG strategy means utilizing expertise and engaging the commitment of employees throughout the entire company. It is important to motivate and empower employees to contribute effectively to the achievement of ESG targets and goals in a way that is relevant to their role.

Incorporating ESG goals within company-wide people management structures, required competencies, performance management systems, and potentially linking with compensation and development plans, is a way of driving greater accountability and progress across the business.

• Answer yes if you can provide evidence that the performance management system of all your company’s relevant employees is linked with the achievement of ESG goals
• Answer partial yes if you can provide evidence that some relevant employees have personal performance objectives linked to the achievement of ESG goals (excluding ESG specific roles where their job is specifically focused 50% or more on this topic)
• Answer no if there is no direct link between ESG targets and your company’s performance management system for employees

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_OQ

Evidence

Provide

• Internal HR, documents and performance management processes and systems that demonstrate how ESG topics are embedded in your company’s management structure and performance review systems (e.g., guidance for managers requiring each person to have an ESG target, documentation).

and

• Evidence of oversight by board/senior leadership (e.g., HR or L&D Director report to board)

Optional supplementary evidence:

• Examples/screenshots of correspondence with employees related to the setting of personal ESG targets
• Screenshots of training materials for reviewing managers on how to set targets aligned with ESG strategy

Topic areas

Performance and incentives

Question: Retailer path

Did your company implement commercial incentives, standards or sanctions for business partners that are linked to environmental, social and governance practices?

Question: Brand and Retailer path

Did your company implement commercial incentives, standards or sanctions for suppliers and/or business partners that are linked to environmental, social and governance practices?

About this question 

This question asks about whether your company has implemented any commercial incentives, sanctions or standards for suppliers and/or business partners in order to support your company’s ESG goals and targets. This could include a scoring system for tender processes that gives preference to suppliers and/or business partners achieving certain ESG goals; offering beneficial terms to enable supplier investment in low carbon technology; sanctions for safety breaches, etc.

• Answer yes if you can provide evidence that your company has embedded ESG in its commercial relationships with all suppliers and/or business partners
• Answer partial yes if you can provide evidence that your company has implemented ESG-linked incentives or sanctions with 2 or more of its significant suppliers or business partners (for example, warehousing or logistics partner) but cannot provide evidence of an overall strategic approach
• Answer no if there is no linking of commercial terms with ESG targets

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_MTA_b (For: Brand, Brand and Retailer)

Reference ID: gsm_MTA_r (For: Retailer)

Evidence

Provide

• Internal procurement documentation setting out how commercial incentives are linked to supplier achievement of ESG standards (e.g., a score card system whereby companies with stronger ESG performance are favored within a tendering exercise)

Topic areas

Performance and incentives

About this question 

Public transparency on key issues is widely recognized as a core principle of good governance. This question asks you to confirm if you have reported your progress in corporate governance topics publicly, for example via an annual report, sustainability report, on your website, or through newsletters about your ESG targets, initiatives and progress.

• Answer yes if you can provide evidence that your company has reported publicly on its corporate governance targets and progress
• Answer no if there has been no public communication of your corporate governance targets and progress, or if there are no targets and/or progress to report on

CRSD:

Companies should be able to disclose the following, related to the reporting period:

Anti-Bribery and Corruption:

1. A description of procedures in place to prevent, detect, and address allegations or incidents of corruption and bribery.
2. Confirmation that investigators or investigating committees are independent of the management chain involved in the matter.
3. The process by which outcomes of investigations are reported to the board.
4. The number of convictions and fines for violations of anti-corruption and anti-bribery laws.
5. Actions taken to address breaches in anti-corruption and anti-bribery standards.
6. The total number and nature of confirmed incidents of corruption or bribery.
7. The number of confirmed incidents where workers were dismissed or disciplined for corruption or bribery-related incidents.
8. The number of confirmed incidents related to business partner contracts terminated or not renewed due to corruption or bribery violations.
9. Details of public legal cases regarding corruption or bribery involving the company or its workers, including outcomes during the reporting period.
10. The nature, scope, and depth of anti-corruption and anti-bribery training programs offered or required by the company.
11. The percentage of functions-at-risk covered by training programs.
12. The extent of training provided to members of the administrative, management, and supervisory bodies.

Lobbying and Political Contributions:

1. Identification of representatives in administrative, management, and supervisory bodies responsible for overseeing these activities.
2. Total monetary value of direct and indirect political contributions, aggregated by country or geographical area and type of recipient/beneficiary.
3. Where applicable, details on how the monetary value of in-kind contributions is estimated.
4. The main topics covered by lobbying activities and the company’s main positions, including their interaction with material impacts, risks, and opportunities.
5. Registration details, if applicable, in the EU Transparency Register or equivalent, including identification numbers.
6. Disclosure of any members of the administrative, management, or supervisory bodies who held comparable positions in public administration in the 2 years preceding their appointment during the reporting period.
7. Total amount paid for membership in lobbying associations.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_MTE

Evidence

Either

• Link to most recent published report (e.g., ESG report, Annual Report and Accounts, corporate governance report, investor relations website)

or

• Third party report on your targets or progress published on your company’s website (e.g., by a consultancy, NGO partner or multi-stakeholder initiative that your company participated in)

Optional supplementary evidence:

• Newsletters or other public communications about your corporate governance programs and progress

Topic areas

Board accountability, transparency

About this question 

This question provides an opportunity to demonstrate that your company takes a collaborative approach to addressing corporate governance risks and opportunities – by working with other businesses (e.g. chambers of commerce), civil society and stakeholders.

While there may be fewer collaborative initiatives focussed on governance topics than other ESG pillars, examples could include participating in roundtables, cross-sector working groups or global collaborations to make progress on challenging corporate governance issues within ESG such as bribery and anti-corruption.

• Answer yes if you can provide evidence that your company has taken part in a joint or collaborative approach to address any corporate governance issue
• Answer no if your company has not participated in collaborative work relating to governance

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_MTI

Evidence

Either

• Link to membership/signatory page, update or annual report published on the website of the relevant multi-stakeholder initiative/s or collaborative group. Pages linked to should indicate the topics addressed and your company’s logo/name and signatory/membership level or contribution during the reporting period

or

• Membership/signatory agreement/s including company’s name and level of commitment to the MSI

and

• Document or link to information indicating how the topic is addressed by the multi-stakeholder initiative/s

Optional supplementary evidence:

• Examples of your company’s data/reporting submission required by the MSI

Topic areas

Stakeholder engagement, transparency

About this question 

To meet their responsibility to respect internationally recognized human rights standards, companies must assess their actual and potential human rights impacts, integrate the findings, and take action to prevent or mitigate potential impacts, track their performance, and communicate their performance. This corporate responsibility must be embedded in the governance structures of a company, with individual board members accountable for human rights across the business. The scope of responsibility for human rights here includes employees, value chain workers, consumers and affected communities.

This question asks you to confirm whether your company has a post at the highest level of the company that holds accountability for human rights (policy, due diligence, implementation, remediation, and reporting). It is considered best practice to disclose the name of this board member/accountable person. This person must be a member of the most senior leadership team in the organization with accountability across all pillars – not an ethical trade manager, sourcing manager, HR manager, or similar role.

• Answer yes if there is a board-level employee accountable for human rights in your company.

• Answer no if no one at board level is held accountable for human rights.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_Mu1

Evidence

Either

• Link to publicly available information setting out accountable persons and governance structures supporting your company’s approach to human rights, for example within an investor portal, ESG report, Human Rights report, or annual report and accounts.

and

• Internal documentation indicating the scope of responsibilty of this individual, for example board papers, job description.

Note: unscored question

About this question 

“This question asks about the systems that your company has in place to support reliable, accurate, complete and transparent sustainability reporting.  By making these disclosures companies are able to meet legal requirements, demonstrate their commitment to sustainability, build trust with stakeholders, and enhance their overall reputation.  However, the process can involve risks, for example around data quality, consistency, availability of evidence, and the need to make assumptions or estimations to fill data gaps. Companies should therefore have effective internal controls in place to identify and manage these risks.  For example, it is essential that all departments involved in the reporting process use agreed methodologies and protocols in data reporting so that there is consistency across the company, and from year to year. The process should be overseen by an accountable person at the most senior level of the business.  Companies should maintain clear and up to date documentation of the risk management and internal control system

• Answer yes if your company can provide evidence of a process of risk management and internal control in relation to sustainability reporting.

• Answer no if your company has no formal process in place to manage the risks associated with sustainability reporting.

Applicability: Brand, Retailer, Brand and Retailer

Reference ID: gsm_Mu2

Evidence

Either

• Internal documentation, setting out the process followed in relation to sustainability reporting.  This should include evidence of board oversight.

CSRD:

• The scope, main features and components of the risk management and internal control processes and systems in relation to sustainability reporting;
• The risk assessment approach followed, including the risk prioritisation methodology;
• The main risks identified and their mitigation strategies including related controls;
• A description of how the company integrates the findings of its risk assessment and internal controls as regards the sustainability reporting process into relevant internal functions and processes; and
• A description of the periodic reporting of the findings referred to in point (d) to the administrative, management and supervisory bodies ..

Note: unscored question