1.1.4. Incident, risk and opportunity management
Information on the materiality assessment process
ESRS 2 IRO-1, ESRS 2 IRO-2
Base and scope
The materiality assessment was conducted in accordance with the requirements of European Commission Delegated Regulation (EU) 2023/2772 on European Sustainability Reporting Standards (ESRS) for a dual materiality assessment. It is also based on the Implementation Guide “Materiality Analysis” of the European Financial Reporting Advisory Group (EFRAG) and the Institute of Accounting and Auditing (ICAC). Viscofan collaborated with an external sustainability consultancy for this assessment.
The methodological process applied is based on the collection of internal information (operational, financial, and sustainability indicators) and external sources (regulatory studies and ESG databases). The working hypotheses include differentiated time horizons (short, medium, and long term), probability criteria derived from regulatory and market scenarios, and severity estimates calculated from the magnitude and reversibility of the impact.
The main objective of this analysis is to identify, firstly, our material impacts on the environment and people according to their importance to stakeholders (impact materiality assessment). Secondly, we have identified the sustainability-related risks and opportunities to which we are exposed according to their importance.
This strategic assessment represents the impact of external factors on our business (financial materiality assessment). The analysis process prioritizes activities and geographies with the greatest exposure to environmental or social risks, particularly energy-intensive industrial operations and relationships with suppliers of natural raw materials in Asia and Latin America, where climatic and social factors are more likely to have an impact.
In the case of our own operations, we identify and assess the impacts on people and the environment, as well as the potential risks to our business posed by sustainability issues. Furthermore, we assess the impacts and risks across the entire value chain, particularly regarding our raw materials, the use and consumption of our products, and the resulting waste. These value chain assessments have been based on internal knowledge and, primarily, on insights from our Tier 1 suppliers.
Viscofan's incidents, risks, and opportunities (IROs) in its own operations and across the value chain can be dynamic and change over time, both for the materials identified in the current materiality analysis and for non-materials. This changing nature is due to multiple factors, such as market fluctuations, regulatory changes, technological advancements, and so on. Therefore, Viscofan has updated its materiality assessment process this year compared to the previous period and plans to conduct periodic reviews of the assessment and materiality using a proactive approach that ensures effective adaptation to changes in the operational and value chain context, while maintaining resilience and responsiveness to new challenges and opportunities. A reasonable and foreseeable timeframe for these reviews could be two years, which would allow for capturing and adjusting to a potentially new reality in a constantly evolving environment.
This report then presents summaries for each material topic, along with detailed descriptions of the impacts, risks, and opportunities identified at the beginning of each thematic standard.
Dual materiality assessment methodology
1. Identification
a. Understanding the internal and external context.
With this scope and with the aim of establishing a basis, an understanding of the context in which Viscofan's business activities and relationships take place has been carried out, and in parallel an understanding of the main stakeholders affected.
This phase has been based on the current strategic plan called Beyond25, the Viscofan Group's risk management and control system, external information made available to the public of both a financial and non-financial nature; policies; the analysis of the materiality of the different comparable companies and the frameworks in matters of sustainability; the sustainability requirements of the different stakeholders, regulators, analysts, ESG indices; and sector studies.
This context analysis has identified environmental, social and governance issues in the operations themselves and upstream and downstream in the value chain that are relevant in the context of Viscofan.
b. Identification of real and potential incidents, risks and opportunities related to sustainability issues
With the analysis of the internal and external context, the list of topics and its alignment with the list of sustainability issues contemplated in the thematic ESRS established in ESRS 1, paragraph AR. 16, has been reviewed.
The identification of internal and external stakeholders has also been carried out, through an understanding of the value chain, and taking into consideration the knowledge of the internal managers of the different areas with influence and affected by the potentially material aspects identified.
In this phase, stakeholder opinions have been considered indirectly through the knowledge of internal managers who maintain ongoing dialogue with these stakeholders and therefore have a good understanding of their interests and perspectives. Furthermore, our continuous engagement with the communities and associations where we operate provides a solid foundation for assessing the most significant impacts and risks for us.
See details of the stakeholder groups and communication channels established in the subsection "interests and opinions of stakeholders" of point 1.1.3 of this ESRS.
In identifying and assessing risks and opportunities in the Viscofan value chain, Viscofan has also considered how it is affected by its dependencies on the availability of natural and social resources at adequate prices and of satisfactory quality.
These risks include, in the environmental dimension, dependence on raw materials of natural origin such as cellulose, abaca paper, and collagen, primarily of bovine origin. A lack of availability of these resources could negatively impact the availability of these raw materials and increase the risk of supply disruptions. In particular, Viscofan's climate scenario analysis focuses on the physical risks that could affect its supply chains and the health of the ecosystems on which it depends. See ESRS E1 and ESRS E5.
In the social dimension, the risk is related to the need for a qualified workforce. See ESRS S1.
2. Materiality assessment. Analysis and determination of material IROs related to sustainability issues
a. Identification of incidents, risks and opportunities
Of the potentially material issues, positive and negative impacts were identified (with an inside-out approach) and risks and opportunities (outside-in approach).
b. Assessment of identified incidents, risks and opportunities and scoring
For this phase, the criteria of those responsible for different areas within Viscofan with extensive experience in sustainability aspects and who are in contact with stakeholders have been considered.
Impact materiality
In assessing the materiality of impacts to determine severity, a scale from 0 (no impact) to 8 (critical) has been established. The following parameters have been taken into account:
- Magnitude: We assess the extent of the impact on the environment, people, or human rights
- Scope: We assess the extent of the impact from a geographical point of view, whether it can be local or global, and which stakeholder groups it affects.
- Irremediable nature: We assess the difficulty of reversing the damage (impact) in terms of cost and time horizon.
Additionally, with regard to the possible impacts, an additional probability parameter and the time horizon have been added.
Based on this, for actual negative impacts, each of the three above dimensions of severity was scored and weighted equally for its severity. Then, severity and probability were weighted 60/40.
In the case of actual positive impacts, scale and scope were scored and weighted equally for severity. Subsequently, severity and probability were weighted 50/50.
Financial materiality
For risks and opportunities, a scale from 0 (no impact) to 5 (critical) was used. The potential magnitude was assessed using two dimensions to evaluate severity. First, how the risks and opportunities would affect business growth and financial statements (Balance Sheet, Profit and Loss Statement, and Cash Flow Statement) was considered using five rating scales. Second, the relational capital dimension was used, that is, how the risk or opportunity would affect relationships with stakeholders, using four rating scales.
Following this severity assessment, probabilities of occurrence have been assigned to obtain the score of the level of financial materiality.
In addition to the quantitative criterion, IROs with relevant qualitative exposure, such as regulatory or reputational risks, are considered material.
c. Thresholds
The materiality thresholds have been defined in accordance with sections 3.3 and 3.4 of ESRS 1, combining quantitative (distribution percentiles) and qualitative criteria.
For impact materiality, the threshold was set at the 50th percentile (p50 = 4.50 out of 8), with impacts considered material if they scored 4.50 or higher or presented relevant qualitative evidence (e.g., human rights or environmental risks). Regarding financial materiality, the threshold was adjusted to the 70th percentile (p70 = 2.40 out of 5), given the concentration of scores in lower ranges and a significant jump above that point.
value. This adjustment responds to the principle of proportionality (ESRS 1, 3.5, paragraphs 47 to 49) and allows focusing on risks and opportunities with significant economic impact.
Finally, it has been defined that material IROs that exceed the indicated scoring thresholds are those whose severity and probability reflect their critical and significant nature for the Viscofan Group for either of the two materialities, both impact and financial.
The thresholds are scheduled to be reviewed every two years or in the event of substantial regulatory changes, under the supervision of the Executive Sustainability Committee and the Audit Committee.
Result of the dual materiality assessment
Subsequently, the results of the impact and financial materiality assessments, including their interaction, were consolidated, grouping the IROs according to their classification across all ESRS themes and, by extension, into the relevant sub-themes. Based on the thresholds established and detailed above, 57 incidents, risks, and opportunities were selected and assessed as material, and these are grouped into the ESRS reported in this sustainability statement.
This consolidation has been reviewed and approved by the Viscofan Group's Executive Sustainability Committee and subsequently presented to the Board of Directors' Audit Committee.
All assessed IROs have been mapped according to their relevant ESRS standard. The highest-scoring impact or risk within a theme determines its placement in the matrix. Six of the ten ESRS themes are significant for Viscofan. Each material ESRS theme is detailed in the table presented earlier in section 1.1.3, where we specify the related sub-themes. The table also indicates whether the IROs are within our own operations or across the value chain, the time horizon, and whether our impacts are positive or negative.
In the environmental category, the environmental incidents, risks and opportunities of relative importance are grouped into the themes E1-Climate Change, E2-Pollution and E5-Use of Resources and Circular Economy and are related to our vision of facilitating the feeding of millions of people thanks to our packaging, which requires an energy-intensive production process that we are seeking to decarbonize, the use of raw materials and resources of natural origin, the dependence on these, as well as the generation of emissions and waste in the production process.
In the social category, the incidents, risks, and opportunities of relative importance are grouped under the themes S1-Own Staff and S4-Consumers and End Users. Our business model also primarily affects the people who work at Viscofan and the consumers of food products manufactured with our casings and other products within the New Businesses division. We focus our efforts on achieving a safe, fair, and inclusive work environment and on producing casings with a focus on excellence in food quality.
Finally, according to the materiality assessment, ESRS G1-Business Conduct is a material issue, and is related to the essential basis that all people in the Group act in accordance with the principles established in the Code of Conduct and in the policies of the Regulatory Compliance System.
List of disclosure requirements to be reported under ESRS
| Standard | Cross-cutting/Thematic | DRs | Description of the DRs | DP | Paragraph |
| ESRS 2 | General information | BP-1 | General basis for the preparation of the sustainability report | 3; 4; 5(a); 5 (b) i.; 5 (b) ii.; 5(c); 5(d); 5(e) | 1.1.1.Basis for presentation |
| ESRS 2 | General information | BP-2 | General basis for the preparation of the sustainability report | 6; 7; 8; 9(a); 9(b); 10(a); 10(b); 10(c); 10(d); 11(a); 11 (b) i.; 11 (b) ii.; 12; 13(a); 13(b); 13(c); 14(a); 14(b); 14(c); 15; 16; 17(a); 17(b); 17(c); 17(d); 17(e); 18 | 1.1.1.Basis for presentation |
| Information relating to specific circumstances | |||||
| Information relating to specific circumstances - Time horizons | |||||
| Information relating to specific circumstances | |||||
| - Value chain estimation | |||||
| Information relating to specific circumstances | |||||
| - Sources of estimation and uncertainty of the result | |||||
| Information relating to specific circumstances | |||||
| - Changes in the preparation or presentation of sustainability information | |||||
| Information relating to specific circumstances | |||||
| - Information on errors from previous periods | |||||
| Information relating to specific circumstances | |||||
| - Information derived from other legislation or generally accepted pronouncements on sustainability reporting | |||||
| - Information relating to specific circumstances - Incorporation by reference | |||||
| - Information relating to specific circumstances - Use of phase-in provisions in accordance with Appendix C of ESRS 1 | |||||
| ESRS 2 | General information | GOV-1 | The role of the administrative, management and supervisory bodies | 19; 20(a); 20(b); 20(c); 21(a); 21(b); 21(c); 21(d); 21(e); 22(a); 22(b); 22 (c) i.; 22 (c) ii.; 22 (c) iii.; 22(d); 23(a); 23(b) | 1.1.2. Governance |
| The role of the administrative, management and supervisory bodies | |||||
| ESRS 2 | General information | GOV-2 | Information provided to the company's administrative, management and supervisory bodies and sustainability issues addressed by them | 24; 25; 26(a); 26(b); 26(c) | 1.1.4. Incident, risk and opportunity management |
| ESRS 2 | General information | GOV-3 | Integrating sustainability-related performance into incentive systems | 27; 28; 29(a); 29(b); 29(c); 29(d); 29(e) | 1.1.2. Governance. Remuneration. Integration of sustainability-related performance into incentive systems. |
| ESRS 2 | General information | GOV-4 | Statement on due diligence | 30; 31; 32; 33 | 1.1.2. Governance. Good governance, due diligence statement and business conduct policies. |
| ESRS 2 | General information | GOV-5 | Risk management and internal controls for the disclosure of sustainability information | 34; 35; 36(a); 36(b); 36(c); 36(d); 36(e); 37(a); 37(b); 37(c) | 1.1.2. Governance. Risk management and internal controls for the disclosure of sustainability information. |
| ESRS 2 | General information | SBM-1 | Strategy, business model and value chain | 38; 39; 40 (a) i.; 40 (a) ii.; 40 (a) iii.; 40 (a) iv.; 40(b); 40(c); 40 (d) i.; 40 (d) ii.; 40 (d) iii.; 40 (d) iv.; 40(e); 40(f); 40(g); 41; 42(a) ; 42(b); 42(c) | 1.1.3. Strategy. Strategy, business model and value chain. |
| ESRS 2 | General information | SBM-2 | Interests and opinions of stakeholders | 43; 44; 45 (a) i.; 45 (a) ii.; 45 (a) iii.; 45 (a) iv.; 45 (a) v.; 45(b); 45 (c) i.; 45 (c) ii.; 45 (c) iii.; 45(d) | 1.1.3. Strategy. Interests and opinions of stakeholders. |
| ESRS 2 | General information | SBM-3 | Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model | 46; 47; 48(a); 48(b); 48 (c) i.; 48 (c) ii.; 48 (c) iii.; 48 (c) iv.; 48(d); 48 (e) i.; 48 (e) ii.; 48(f); 48(g); 48 (h); 49; 50(a); 50(b) | 1.1.3. Strategy. Incidents, risks and opportunities of relative importance, their interaction with the strategy and business model, and current and expected financial effects. |
| ESRS 2 | General information | IRO-1 | Description of the process for determining and evaluating incidents, risks, and opportunities of relative importance | 51; 52; 53(a); 53 (b) i.; 53 (b) ii.; 53 (b) iii.; 53 (b) iv.; 53 (c) i.; 53 (c) ii.; 53 (c) iii.; 53(d); 53(e); 53(f); 53(g); 53 (h) | 1.1.4. Incident, risk and opportunity management. Information on the materiality assessment process. |
| ESRS 2 | General information | IRO-2 | Disclosure requirements set out in the ESRS covered by the company's sustainability statement | 54; 55; 56; 57; 58; 59; 60; 61; 62; | 1.1.4. Incident, risk and opportunity management. Result of the dual materiality assessment. |
| ESRS 2 | General information | MDR-P | Policies adopted to manage sustainability issues of relative importance | 63; 64; 65(a); 65(b); 65(c); 65(d); 65(e); 65(f) | Policies related to each of the material issues. |
| Climate change | |||||
| Pollution. | |||||
| Use of resources and the circular economy. | |||||
| Own staff. | |||||
| ESRS 2 | General information | MDR-A | Actions and resources related to sustainability issues of relative importance | 66; 67; 68(a); 68(b); 68(c); 68(d); 68(e); 69(a); 69(b); 69(c); 70; 71; 72 | Actions and resources related to each of the material issues. Climate change |
| Pollution | |||||
| Resource use and the circular economy | |||||
| Own staff | |||||
| Consumers and end users. | |||||
| ESRS 2 | General information | MDR-M | Parameters related to sustainability issues of relative importance | 73; 74; 75; 76; 77(a); 77(b); 77(c); 77(d) | Parameters and related to each of the material topics. |
| Climate change | |||||
| Pollution | |||||
| Resource use and the circular economy | |||||
| Own staff | |||||
| ESRS 2 | General information | MDR-T | Monitoring the effectiveness of policies and actions through goals | 78; 79(a); 79(b); 79(c); 79(d); 79(e); 80(a); 80(b); 80(c); 80(d); 80(e); 80(f); 80 (g); 80 (h); 80 (i); 80(j); 81(a) ; 81 (b) i.; 81 (b) ii. | Consumers and end users. |
| ESRS E1 | Climate change | GOV-3 | Integrating sustainability-related performance into incentive systems | 13 | 2.1.2. Governance |
| ESRS E1 | Climate change | E1-1 | Transition plan for climate change mitigation | 14; 15; 16(a); 16(b); 16(c); 16(d); 16(e); 16(f); 16(g); 16 (h); 16(i); 16(j); 17 | 2.1.3. Strategy |
| Transition plan for climate change mitigation. | |||||
| ESRS E1 | Climate change | SBM-3 | Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model | 18; 19 (a); 19 (b); 19 (c) | 2.1.3. Strategy |
| ESRS E1 | Climate change | IRO-1 | Description of the processes for determining and evaluating climate-related incidents, risks, and opportunities of relative importance | 20(a); 20 (b) i.; 20 (b) ii.; 20 (c) i.; 20 (c) ii.; 21 | 2.1.4. Incident, risk and opportunity management |
| ESRS E1 | Climate change | E1-2 | Policies related to climate change mitigation and adaptation | 22; 23; 24; 25(a); 25(b); 25(c); 25(d); 25(e) | 2.1.4. Incident, risk and opportunity management |
| ESRS E1 | Climate change | E1-3 | Actions and resources related to climate change policies | 26; 27; 28; 29(a); 29(b); 29 (c) i.; 29 (c) ii.; 29 (c) iii. | 2.1.4. Incident, risk and opportunity management |
| ESRS E1 | Climate change | E1-4 | Goals related to climate change mitigation and adaptation | 30; 31; 32; 33; 34(a); 34(b); 34(c); 34(d); 34(e); 34(f) | 2.1.5. Parameters and goals |
| ESRS E1 | Climate change | E1-5 | Energy consumption and combination | 35; 36; 37(a); 37(b); 37 (c) i.; 37 (c) ii.; 37 (c) iii.; 38(a); 38(b); 38(c); 38(d); 38(e); 39; 40; 41; 42; 43 | 2.1.5. Parameters and goals |
| Energy consumption and mix - Energy intensity based on net income | |||||
| ESRS E1 | Climate change | E1-6 | Gross scope 1, 2 and 3 GHG emissions and total GHG emissions | 44(a); 44(b); 44(c); 44(d); 45(a); 45(b); 45(c); 45(d); 46; 47; 48(a); 48(b); 49(a); 49(b); 50(a); 50(b); 51; 52(a); 52(b); 53; 54; 55 | 2.1.5. Parameters and goals |
| GHG intensity based on net income | |||||
| ESRS E1 | Climate change | E1-7 | GHG removals and GHG mitigation projects financed through carbon credits | 56(a); 56(b); 57(a); 57(b); 58(a); 58(b); 59(a); 59(b); 60; 61(a); 61(b); 61(c) | 2.1.5. Parameters and goals |
| ESRS E1 | Climate change | E1-8 | Internal carbon pricing system | 62; 63(a); 63(b); 63(c); 63(d) | 2.1.5. Parameters and goals |
| ESRS E1 | Climate change | E1-9 | Expected financial effects of significant physical and transition risks and potential opportunities related to climate change | 64(a); 64(b); 64(c); 65(a); 65(b); 66(a); 66(b); 66(c); 66(d); 67(a); 67(b); 67(c); 67(d); 67(e); 68(a); 68(b); 69(a); 69(b); 70 | 2.1.5. Parameters and goals |
| ESRS E2 | Pollution | IRO-1 | Description of the processes for determining and evaluating incidents, risks, and opportunities of relative importance related to pollution | 11(a); 11(b) | 2.2.1. Incident, risk and opportunity management |
| ESRS E2 | Pollution | E2-1 | Policies related to pollution | 12; 13; 14; 15(a); 15(b); 15(c) | 2.2.1. Incident, risk and opportunity management |
| ESRS E2 | Pollution | E2-2 | Actions and resources related to pollution | 16; 17; 18; 19(a); 19(b); 19(c) | 2.2.1. Incident, risk and opportunity management |
| ESRS E2 | Pollution | E2-3 | Pollution-related goals | 20; 21; 22; 23(a); 23(b); 23(c); 23(d); 24(a); 24(b); 24(c); 25 | 2.2.2. Parameters and goals |
| ESRS E2 | Pollution | E2-4 | Air, water and soil pollution | 26; 27; 28(a); 28(b); 29; 30(a); 30(b); 30(c); 31 | 2.2.2. Parameters and goals |
| ESRS E2 | Pollution | E2-5 | Substances of concern and substances of very high concern | 32; 33; 34; 35 | 2.2.2. Parameters and goals |
| ESRS E2 | Pollution | E2-6 | Expected financial effects of material risks and opportunities related to pollution | 36; 37; 38(a); 38(b); 39(a); 39(b); 39(c); 40(a); 40(b); 40(c); 41 | 2.2.1. Incident, risk and opportunity management |
| ESRS E5 | Circular economy | IRO-1 | Description of the processes for determining and evaluating the incidents, risks, and opportunities of relative importance related to resource use and the circular economy | 11(a); 11(b) | 2.3.1. Incident, risk and opportunity management |
| ESRS E5 | Circular economy | E5-1 | Policies related to resource use and the circular economy | 12; 13; 14; 15(a); 15(b); 16 | 2.3.1. Incident, risk and opportunity management |
| ESRS E5 | Circular economy | E5-2 | Actions and resources related to the use of resources and the circular economy | 17; 18; 19; 20(a); 20(b); 20(c); 20(d); 20(e); 20 (f) | 2.3.1. Incident, risk and opportunity management |
| ESRS E5 | Circular economy | E5-3 | Goals related to resource use and the circular economy | 21; 22; 23; 24(a); 24(b); 24(c); 24(d); 24(e); 24(f); 25; 26(a); 26(b); 26(c); 27 | 2.3.2. Parameters and goals |
| ESRS E5 | Circular economy | E5-4 | Resource inputs | 28; 29; 30; 31(a); 31(b); 31(c); 32 | 2.3.2. Parameters and goals |
| ESRS E5 | Circular economy | E5-5 | Resource outputs | 33; 34(a); 34(b); 35; 36(a); 36(b); 36(c); 37(a); 37(b)i; 37(b)ii; 37(b)iii; 37(c)i; 37(c)ii; 37(c)iii; 37(d); 38(a); 38(b); 39; 40 | 2.3.2. Parameters and goals |
| Resource outputs - Products and materials | |||||
| Resource outputs - Waste | |||||
| ESRS E5 | Circular economy | E5-6 | Expected financial effects of material risks and opportunities related to resource use and the circular economy | 41; 42(a); 42(b); 43(a); 43(b); 43(c) | 2.3.2. Parameters and goals |
| ESRS S1 | Own staff | SBM-2 | Interests and opinions of stakeholders | 12 | 3.1.1. Strategy |
| ESRS S1 | Own staff | SBM-3 | Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model | 13(a); 13(b); 14(a); 14(b); 14(c); 14(d); 14(e); 14 (f) i.; 14 (f) ii.; 14 (g) i.; 14 (g) ii.; 15; 16 | 3.1.1. Strategy |
| ESRS S1 | Own staff | S1-1 | Policies related to own staff | 17; 18; 19; 20(a); 20(b); 20(c); 21; 22; 23; 24(a); 24(b); 24(c); 24(d) | 3.1.2. Incident, risk and opportunity management |
| ESRS S1 | Own staff | S1-2 | Processes for collaborating with staff and employee representatives on incident matters | 25; 26; 27(a); 27(b); 27(c); 27(d); 27(e); 28; 29 | 3.1.2. Incident, risk and opportunity management |
| ESRS S1 | Own staff | S1-3 | Processes for addressing negative incidents and channels for staff to express their concerns | 30; 31; 32(a); 32(b); 32(c); 32(d); 32(e); 33; 34 | 3.1.2. Incident, risk and opportunity management |
| ESRS S1 | Own staff | S1-4 | Adoption of measures related to material incidents involving own staff, approaches to managing material risks and taking advantage of material opportunities related to own staff, and the effectiveness of such actions | 35; 36(a); 36(b); 37; 38(a); 38(b); 38(c); 38(d); 39; 40(a); 40(b); 41; 42; 43 | 3.1.2. Incident, risk and opportunity management |
| ESRS S1 | Own staff | S1-5 | Goals related to the management of significant negative incidents, the promotion of positive incidents, and the management of significant risks and opportunities | 44(a); 44(b); 44(c); 45; 46; 47(a); 47(b); 47(c) | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-6 | Characteristics of the company's employees | 48; 49; 50(a); 50 (b) i.; 50 (b) ii.; 50 (b) iii.; 50(c); 50 (d) i.; 50 (d) ii.; 50(e); 50(f); 51; 52(a); 52(b) | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-7 | Characteristics of non-salaried workers within the company's own staff | 53; 54; 55(a); 55 (b) i.; 55 (b) ii.; 55(c); 56; 57 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-8 | Coverage of collective bargaining and social dialogue | 58; 59; 60(a); 60(b); 60(c); 61; 62; 63(a); 63(b) | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-9 | Diversity parameters | 64; 65; 66 (a); 66 (b) | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-10 | Adequate wages | 67; 68; 69; 70; 71 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-11 | Social protection | 72; 73; 74(a); 74(b); 74(c); 74(d); 74(e); 75; 76 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-12 | People with disabilities | 77; 78; 79; 80 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-13 | Parameters for training and capacity building | 81; 82; 83(a); 83(b); 84; 85 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-14 | Health and safety parameters | 86; 87; 88(a); 88(b); 88(c); 88(d); 88(e); 89; 90 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-15 | Work-life balance parameters | 91; 92; 93 (a); 93 (b); 94 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-16 | Remuneration parameters (salary gap and total remuneration) | 95; 96; 97(a); 97(b); 97(c); 98; 99 | 3.1.3. Parameters and goals |
| ESRS S1 | Own staff | S1-17 | Incidents, complaints and serious human rights-related issues | 100; 101; 102; 103(a); 103(b); 103(c); 103(d); 104(a); 104(b) | 3.1.3. Parameters and goals |
| ESRS S4 | Consumers and end users | SBM-2 | Interests and opinions of stakeholders | 8 | 3.2.1. Strategy |
| ESRS S4 | Consumers and end users | SBM-3 | Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model | 9(a); 9(b); 10 (a) i.; 10 (a) ii.; 10 (a) iii.; 10 (a) iv.; 10(b); 10(c); 10(d); 11; 12 | 3.2.1. Strategy |
| ESRS S4 | Consumers and end users | S4-1 | Policies related to consumers and end users | 13; 14; 15; 16(a); 16(b); 16(c); 17 | 3.2.2. Incident, risk and opportunity management |
| ESRS S4 | Consumers and end users | S4-2 | Processes for collaborating with consumers and end users regarding incidents | 18; 19; 20(a); 20(b); 20(c); 20(d); 21; 22 | 3.2.2. Incident, risk and opportunity management |
| ESRS S4 | Consumers and end users | S4-3 | Processes for addressing negative incidents and channels for consumers and end users to express their concerns | 23; 24; 25(a); 25(b); 25(c); 25(d); 26; 27 | 3.2.2. Incident, risk and opportunity management |
| ESRS S4 | Consumers and end users | S4-4 | Adoption of measures related to material incidents affecting consumers and end users, approaches to managing material risks and taking advantage of material opportunities related to consumers and end users, and the effectiveness of such actions | 28; 29(a); 29(b); 30; 31(a); 31(b); 31(c); 31(d); 32(a); 32(b); 32(c); 33(a); 33(b); 34; 35; 36; 37 | 3.2.2. Incident, risk and opportunity management |
| ESRS S4 | Consumers and end users | S4-5 | Goals related to the management of significant negative incidents, the promotion of positive incidents, and the management of significant risks and opportunities | 38(a); 38(b); 38(c); 39; 40; 41(a); 41(b); 41(c) | 3.2.3. Parameters and goals |
| ESRS G1 | Business conduct | GOV-1 | The role of the administrative, management and supervisory bodies | 5 (a); 5 (b) | 4.1.1. Governance |
| ESRS G1 | Business conduct | IRO-1 | Description of the processes for determining and evaluating incidents, risks, and opportunities of relative importance | 6 | 4.1.2. Incident, risk and opportunity management |
| ESRS G1 | Business conduct | G1-1 | Business conduct policies and corporate culture | 7; 8; 9; 10(a); 10(b); 10 (c) i.; 10 (c) ii.; 10(d); 10(e); 10(f); 10(g); 10 (h); 11 | 4.1.2. Incident, risk and opportunity management |
| ESRS G1 | Business conduct | G1-2 | Supplier relationship management | 12; 13; 14; 15 (a); 15 (b) | 4.1.2. Incident, risk and opportunity management |
| ESRS G1 | Business conduct | G1-3 | Prevention and detection of corruption and bribery | 16; 17; 18(a); 18(b); 18(c); 19; 20; 21(a); 21(b); 21(c) | 4.1.2. Incident, risk and opportunity management |
| ESRS G1 | Business conduct | G1-4 | Confirmed cases of corruption or bribery | 22; 23; 24(a); 24(b); 25(a); 25(b); 25(c); 25(d); 26 | 4.1.3. Parameters and goals |
List of data points included in cross-cutting standards and in thematic standards derived from other EU legislation
In developing the Sustainability Statement, aspects arising from other EU legislation unrelated to the Group's sector of activity have not been taken into account, such as Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure in the financial services sector (OJ L 317, 9.12.2019, p. 1), Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (Capital Requirements Regulation, 'CRR') (OJ L 176, 27.6.2013, p. 1), and Regulation (EU) 2016/1011 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (Capital Requirements Regulation, 'CRR') (OJ L 176, 27.6.2013, p. 1). (6) European and Council Regulation (EU) 2016/649 of 8 June 2016 on indices used as a reference in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1) and Commission Implementing Regulation (EU) 2022/2453 of 30 November 2022 amending the implementing technical standards laid down in Implementing Regulation (EU) 2021/637 as regards the disclosure of information on environmental, social and governance risks (OJ L 324, 19.12.2022, p. 1).
The cross-cutting standards for the material aspects taken into account are as follows:
| Disclosure requirement and related data point | Reference to the Regulation on benchmark indices (3) | Reference to European Climate Legislation (4) | Reference |
| ESRS 2 GOV-1 Gender diversity of the board of directors section 21, letter d) | Commission Delegated Regulation (EU) 2020/1816 (5), Annex II | GOV-1: The role of the administrative, management and supervisory bodies | |
| ESRS 2 GOV-1 Percentage of council members who are independent, paragraph 21 e) | Delegated Regulation (EU) 2020/1816, Annex II | GOV-1: The role of the administrative, management and supervisory bodies | |
| ESRS 2 SBM-1 Participation in activities relating to fossil fuels section 40, letter d), subparagraph i) | Delegated Regulation (EU) 2020/1816, Annex II | SBM-1: Strategy, business model and value chain | |
| ESRS 2 SBM-1 Participation in activities related to the production of chemical substances section 40, letter d), subparagraph ii) | Delegated Regulation (EU) 2020/1816, Annex II | SBM-1: Strategy, business model and value chain | |
| ESRS 2 SBM-1 Participation in activities related to controversial weapons section 40, letter d), subparagraph iii) | Delegated Regulation (EU) 2020/1818 (7), Article 12(1) Delegated Regulation (EU) 2020/1816, Annex II | SBM-1: Strategy, business model and value chain | |
| ESRS 2 SBM-1 Participation in activities related to the cultivation and production of tobacco, section 40, letter d), subsection iv) | Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1; Delegated Regulation (EU) 2020/1816, Annex II | SBM-1: Strategy, business model and value chain | |
| ESRS E1-1 Transition plan to achieve climate neutrality by 2050 section 14 | Regulation (EU) 2021/1119, Article 2, paragraph 1 | E1-1: Transition plan for climate change mitigation | |
| ESRS E1-1 Companies excluded from the benchmark indices harmonised with the Paris Agreement paragraph 16(g) | Delegated Regulation (EU) 2020/1818, Article 12(1)(d) to (g), and Article 12(2) | E1-1: Transition plan for climate change mitigation | |
| ESRS E1-4 GHG emissions reduction targets section 34 | Delegated Regulation (EU) 2020/1818, Article 6 | E1-4: Goals related to climate change mitigation and adaptation | |
| ESRS E1-6 Gross scope 1, 2 and 3 GHG emissions and total GHG emissions section 44 | Delegated Regulation (EU) 2020/1818, Article 5(1), and Articles 6 and 8(1) | E1-6: Gross scope 1, 2 and 3 GHG emissions and total GHG emissions | |
| ESRS E1-6 Gross GHG emission intensity sections 53 to 55 | Delegated Regulation (EU) 2020/1818, Article 8, paragraph 1 | E1-6: Gross scope 1, 2 and 3 GHG emissions and total GHG emissions | |
| ESRS E1-7 GHG uptake and carbon credits section 56 | Regulation (EU) 2021/1119, Article 2, paragraph 1 | E1-7: GHG removals and GHG mitigation projects financed through carbon credits | |
| ESRS S1-1 Due diligence policies regarding matters covered by Fundamental Conventions 1 to 8 of the International Labour Organization, paragraph 21 | Delegated Regulation (EU) 2020/1816, Annex II | S1-1: Policies related to own staff | |
| ESRS S1-14 Number of fatalities and number and rate of work accidents section 88, letters b) and c) | Delegated Regulation (EU) 2020/1816, Annex II | S1-14: Health and safety parameters | |
| ESRS S1-16 Gender pay gap, unadjusted section 97(a) | Delegated Regulation (EU) 2020/1816, Annex II | S1-16: Remuneration parameters (salary gap and total remuneration) | |
| ESRS S1-17. Non-compliance with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines, paragraph 104(a) | Delegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 | S1-17: Incidents, complaints and serious human rights-related incidents | |
| ESRS S1-1. Non-compliance with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines, section 19 | Delegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 | S1-1: Policies related to own staff and MDR-P Good governance, due diligence statement and business conduct policies in 1.1.2. Governance | |
| ESRS S4-1 Non-compliance with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines, section 17 | Delegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 | S4-1: Policies related to consumers and end users | |
| ESRS G1-4 Fines for breaching anti-corruption and bribery laws, paragraph 24(a) | Delegated Regulation (EU) 2020/1816, Annex II | G1-4: Goals, Zero cases of corruption or bribery |
Viscofan Group's global process for incident and risk management
ESRS 2 IRO-1 and ESRS 2 GOV-2
Incident and risk management ensures a balance between the desire to create value for our stakeholders and the incidents and risks associated with business, commercial, operational, labor, financial and social initiatives, as established by the sustainability policy.
The governing, management, and supervisory bodies play a fundamental role in considering issues, risks, and opportunities when overseeing the Sustainability Strategy and Action Plan, as well as decisions on major operations and the risk management process. This is carried out through the specific responsibilities assigned to them, which are detailed at the Board Committee level, at the management level, and on specific issues in various committees. Their comprehensive approach ensures that the company's strategy is aligned with its objectives and that issues, risks, and opportunities are managed effectively.
The incident and risk management system is the responsibility of the Board of Directors, which delegates its supervision and proper functioning to the Audit Committee. Likewise, within the Viscofan Group, there are various bodies responsible for the supervision and control of different risks that, with varying levels of occurrence and materiality, may arise during the course of Viscofan's activities:
- Internal Audit: Its function is to promote the application of risk management in all activities and to ensure that relevant risks are properly identified, assessed, managed, and controlled. It has a significant presence on specific committees.
- Ethics and Regulatory Compliance Committee: is the body responsible for monitoring the Group's specific risks in relation to criminal liability or any other non-compliance, and for evaluating, implementing and monitoring the Regulatory Compliance System.
- Global Risk Committee: This is a body whose purpose is to identify and assess the main risks of the Viscofan Group, delving into the organisation's exposure to them in order to formulate the recommendations and actions necessary for their management within the established limits.
- Credit Risk Committee: This committee is established as a body for the control and supervision of risks related to customer debt collection. Its objective is to enhance the prevention, monitoring, and resolution of these risks through the creation and implementation of the most appropriate instruments at any given time.
- Investment Committee: Its main objective is to control and monitor compliance with the Investment Plan approved by the Board of Directors. To this end, it meets quarterly to regularly track the proper implementation of approved investments and to monitor the efficiency of resource and investment use within the Group.
- Information Security and Artificial Intelligence Committee: The Committee is responsible for validating the internal rules and procedures proposed by the Information Security Director, supervising risk management, continuity and incident response plans, approving exceptions and exemptions proposed by the Information Security Director in accordance with section 9 of the Information Security Policy and establishing the framework for relations with the audit and internal control functions.
- Executive Sustainability Committee: is the body responsible for coordinating and supervising the Sustainability Action Plan, the initiatives, work plans and long-term objectives established therein.
- Senior management is responsible for identifying and assessing the risks and incidents the Group faces in the course of its operations and for taking appropriate measures to prevent their occurrence or, if they do occur, to reduce or eliminate their impact. Senior management therefore plays a fundamental role in designing and implementing control mechanisms, as well as in promoting their compliance throughout the organisation.
Viscofan has a risk control and management policy whose objective is to establish the basic principles and the general framework for action to identify, measure, prevent and mitigate risks of all kinds that may affect the achievement of strategic objectives, including those related to people and the environment.
Viscofan uses a comprehensive management and control system that is applied in all companies and is developed in accordance with the basic principles of integration in management, adaptation to changes, transparency and adoption of continuous improvement.
Incidents and potential risks are considered when monitoring and adjusting the company's strategy as a basis for making decisions that strengthen resilience and allow proactive adaptation to market changes.
The values of risk indicators and thresholds defined according to their severity and probability are monitored, so that in cases where these thresholds have been exceeded, the necessary management measures are taken to bring them back to the defined tolerance level. Viscofan seeks to strengthen the control system by promoting a solid business model that allows incidents and risks to be addressed in a controlled manner.
The objective of incident and risk management is to identify and assess events as soon as possible, taking into account the Code of Conduct, internal regulations, the strategic plan, and continuous contact with stakeholders, and thus take appropriate measures to mitigate them, and which in some cases may present opportunities.
The governing and supervisory bodies also promote a risk management culture throughout the organisation. Through training and clear policies, efforts are made to ensure that everyone understands the importance of identifying and reporting risks and incidents promptly. Furthermore, regular audits and compliance reviews are conducted to ensure that risk control measures are effective and kept up to date. This proactive approach allows Viscofan not only to react to incidents and risks but also to anticipate potential threats, thereby maintaining a competitive advantage and ensuring long-term sustainability.
The system includes the following activities:
- Identify the main risks based on their impact on creating sustainable and shared value for Viscofan Group stakeholders within the current Strategic Plan, and assess their probability of occurrence and impact to prioritize them accordingly, considering both financial and non-financial or sustainability factors. The system also takes into account the connections and dependencies between incidents and risks and opportunities.
- Set risk appetite by establishing tolerances and properly monitoring their evolution with key risk indicators used as input parameters depending on each risk.
- Implement an integrated control system within the Viscofan Group's internal regulations, including the identification and evaluation of the controls and contingency plans necessary to mitigate the impact of the materialization of risks.
- To evaluate the effectiveness of the control system and its application, as well as its compliance by all Viscofan Group employees.
- Determine action plans in the event that any of the risks adversely affect long-term sustainable value creation and reduce the residual risk to an acceptable level. As a direct consequence of this risk reduction, it will be necessary and advisable to reassess and prioritize risks, establishing a continuous management process.
- The system will be audited by the Internal Audit Department.
Viscofan's risk map is defined in accordance with the code of conduct, internal regulations and the current Strategic Plan and includes risks of various natures (market, business, operational, credit, social, environmental, climate change, technological, legal and regulatory), which are classified according to the COSO methodology into four main categories according to the nature of the objectives they affect: strategic, operational, information and compliance.
Information regarding incident and risk management is detailed in section E) of the Annual Corporate Governance Report. In this section, the Viscofan Group describes the main financial and non-financial risks, the bodies responsible for developing and implementing the financial and non-financial risk management system, the level of risk tolerance, the risks that materialized during the year, and the response and monitoring plans for the main risks.