Comprehensive but concise
The Directive
foresees that companies report on
all information that is necessary for an understanding of the company's development, performance, position and
impact. The non-financial statement is also expected to be concise.
Legal base
"[...] shall include in the management report a non-financial statement containing information to the extent necessary for an understanding of the undertaking's development, performance, position and impact of its activity, relating to, as a minimum, environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters [...]"
A company may summarize information, focus on material information, remove generic information, limit details, avoid elements that are no longer relevant, use cross-reference and signposting, etc.
The Directive foresees that the non-financial statement should include all information that is necessary for an understanding of a company's development, performance, position and impact.
Material information on certain categories of issues explicitly reflected in the Directive should be disclosed as a minimum: environmental, social and employee matters, respect of human rights, anti-corruption and bribery matters. Companies should also disclose information on any other issues to the extent that such information would be material.
Disclosures are expected to be comprehensive. This refers to the breadth of information disclosed. However, information does not need to be exhaustive for the statement to be considered comprehensive. The depth of information reported on any particular issue depends on its materiality. Companies should focus their efforts on the information that is more relevant to understand their development, performance, position and the impact of their activity.
The non-financial statement is also expected to be concise, and avoid immaterial information. Including such immaterial information could impair the understandability of the non-financial statement, by obscuring material information. Generic or boilerplate information that is not material to the company should be avoided.
In order to achieve conciseness, the non-financial statement may include internal cross references or signposting in order to limit repetition, and provide links to other information.