SwissHoldings is pleased to provide comments on the Exposure Draft (ED). As stated in its comment letter to the IFRS Foundation Trustees Consultation Paper Sustainability Reporting, SwissHoldings welcomes the initiative to extend the activities of the IFRS towards sustainability reporting. The current situation with a wide variety of demands of sustainability related information and a large number of optional metrics, standards, indexes and reporting frameworks has become an increasing challenge for reporting entities with growing administrative costs as a result.

A global set of internationally recognized sustainability reporting standards would help with the consolidation and convergence of sustainability reporting standards and ensure a more level-playing field for companies operating globally. It would thus lead to more cost-efficient reporting and help to remove duplicating or contradictory reporting requirements. Furthermore, a harmonised standard would increase comparability and transparency of reports, where this is necessary and feasible.

In our opinion, the IFRS Foundation is well positioned to play a lead role in the standard-setting efforts, acknowledging the importance of materiality and building on the main sustainability frameworks and standards that already exist.

Based on this, we provide our comments in relation to the specific questions raised in the ED following the position of BUSINESSEUROPE in the annex.

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