Our Position

Non-binding guidelines on non-financial reporting

Response to the European Commission on non-binding guidelines on non-financial reporting.

Eurocadres is the trade union voice of almost six million professionals and managers. We voice the interests of professionals and managers through social dialogue, advocacy and lobbying as well as through our networks, joint work with member organisations and cooperation with partners.

Eurocadres thanks the Commission for the possibility of giving input in the elaboration of the non-binding guidelines on non-financial reporting.

Eurocadres welcomes the issuance of guidelines on non-financial reporting. We have participated in the public consultation of April 2016 and in the two open consultations by DG FISMA, the last being held on February 16th, 2017.

On the general principles, we would like to line out that principle “consistent and coherent” is very important and we would like to advocate to include a reference to social reporting (“bilan social”). This would ensure better comparability between figures provided for works councils (national and especially European works councils) and those published in the annual report.

On the thematic issues, we note favourably that the notion of supply chains is included explicitly in the guidelines. Reference to frameworks and guidelines should also include the recent work of the ILO concerning that topic.

Concerning board diversity, it is stated in the objectives that companies should define and disclose specific measurable targets with respect to relevant diversity aspects. These aspects should also include “fit & proper” criteria in order to determine their competence.