In a nutshell, our main points for consideration are the following:

  • SwissHoldings acknowledges and supports the aim to foster consistency by reducing fragmentation and increasing comparability regarding non-financial reporting. Companies need to be at the heart of this process which is why we favour a market-driven approach. The private sector constantly reviews and evaluates its sustainability efforts. This is directly reflected in the non-financial reporting which is subject to a lot of dynamic and company-led initiatives developing the area. A good example in this regard is the Value Balancing Alliance Approach. Such market-driven approaches should not be hindered through a inflexible mandatory “one size fits all”-approach. Therefore, we strongly avocate against an additional ‘standard’ at EU level for non-financial reporting. Such a standard might potentially prove harmful to developments of non-financial reporting.
  • Established standards hardly consider information about company’s contributions to the economic development of a society, such as the company’s contribution to GDP, the number of jobs created or the contribution to the pension system. However, this economic contribution plays a major role in sustainable development as it is also set out in the principles of the triple bottom line. Consideration should be given to how such criteria could be better included in the reporting frame.
  • An internationally coordinated approach creating a level-playing field within and outside the EU should be chosen. It is decisive to incorporate existing standards to not create further fragmentation.

See detailed response (pdf)

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