Minimum disclosure requirement - Policies MDR-P – Policies adopted to manage material sustainability matters

63. The undertaking shall apply the minimum disclosure requirements defined in this provision when it discloses the policies it has in place with regard to each sustainability matter identified as material.

64. The objective of this Minimum Disclosure Requirement is to provide an understanding of the policies that the undertaking has in place to prevent, mitigate and remediate actual and potential impacts, to address risks and to pursue opportunities.

65. The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information:

    • (a) a description of the key contents of the policy, including its general objectives and which material impacts, risks or opportunities the policy relates to and the process for monitoring;

    • (b) a description of the scope of the policy, or of its exclusions, in terms of activities, upstream and/or downstream value chain, geographies and if relevant, affected stakeholder groups;

    • (c) the most senior level in the undertaking’s organization that is accountable for the implementation of the policy;

    • (d) a reference, if relevant, to the third-party standards or initiatives the undertaking commits to respect through the implementation of the policy;

    • (e) if relevant, a description of the consideration given to the interests of key stakeholders in setting the policy; and

    • (f) if relevant, whether and how the undertaking makes the policy available to potentially affected stakeholders, and stakeholders who need to help implement it.