Basis for Preparation CSRD - x6 companies compared

February 24, 2025

In my goal to understand Best in Class CSRD reporting this week the focus is on the opening of company reports, the “Basis for Preparation.” The goal of this is to consider how the companies reported on their Basis for Preparation.

For this analysis, I look at the following x6 companies reports. Below I link their reports and share what page their Basis for Preparation begins.

Kemira: Page 83

BAM: Page 72

Heineken: Page 149

Airbus: Page 129

ISS World: Page 57

Sartorious Group: Page 111

What does the CSRD regulation require for the Basis for Preparation:

The following is a screenshot from the CSRD regulation regarding what should be in the basis for preparation:

I’ve broken this down into the key requirements a company should include and follow these requirements within this article. Below we look at how each of the x6 companies cover these topics.

Objective: How was the sustainability statement prepared / is it consolidated or individual (All are consolidated)

Scope of Consolidation - Upstream and Downstream Value Chain Data

Omitted information

Sources of Estimation

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Interesting Aspects of CSRD Reporting to Highlight

At the bottom of this article we provide screenshots to each of these companies Basis of Preparation. Before we break down the disclosure more, some interesting aspects to highlight:

Every company from this group reported on a consolidated basis that matched their financial reporting.

Ending GRI Reporting:

Kemira shares why they did not do GRI aligned reporting: As of 2024, Kemira will no longer publish a separate Sustainability Report based on the Global Reporting Initiative (GRI). As the disclosure requirements between CSRD and GRI differ, some previously reported KPIs and metrics required by GRI will no longer be reported in this Sustainability Statement. Kemira has compiled a GRI index to ease the transition to CSRD reporting. The GRI index is available on Kemira's website.

No past year data comparison:

BAM confirms they will not offer past year data comparison as this is the first ESRS year:
As this is the first year of application of ESRS, no specific comparison can be made with previous years in terms of scope and reporting boundaries. Comparative figures have been disclosed in line with current year reporting principles and assumptions, and any topic specific deviations are disclosed. BAM anticipates that comparatives become progressively available after the first year of reporting which will make the sustainability information presented in the sustainability statement more useful.

Both ISS World and Sartorius mention an expectation that data quality can improve over time.

ISS World comments around how they expect data quality to improve over time. Scope and data quality In 2024, preparations for reporting in accordance with the Corporate Sustainability Reporting Directive (CSRD) and the associated ESRS reporting standards have been extensive and while a foundation has been laid we expect ongoing changes as practices and principles develop across reporters, industries, regulators and assurance providers.

Sartorius mentions challenges with missing data due to this being the first year of reporting ESRS data. As the ESRS has not yet been applied for several years, preparing the Sustainability Statement for the first time was associated with uncertainties with regard to open questions and related interpretations. The company has taken information into account that was available by January 31, 2025. As indicated in the relevant places, the Sustainability Statement contains estimates that can only be refined in future reporting periods when more relevant information from the value chain and from the Group’s own operations is available. These can only emerge as the number of undertakings subject to reporting requirements increases and reporting practices become more established, making sector benchmarks and comparisons possible. In the meantime, Sartorius has transparently disclosed all key assumptions, judgments and thresholds, such as those used to define the value chain and end users, perform the double materiality assessment and establish the metrics, at the relevant points in the Statement to provide readers with an understanding of the accuracy of the reporting.

Scope of Consolidation:

Kemira: The consolidated sustainability information comprises the parent company Kemira Oyj and subsidiaries controlled by Kemira Oyj. Subsidiaries are all legal entities that Kemira Oyj has control over, as defined in the Financial Statements (in note 6.2. The Group’s subsidiaries and investments in associates). The Scope of consolidation is the same as for the Financial Statements but associates are not included in the sustainability reporting. Consolidation of all sustainability data follows the principles above, unless otherwise specified. The Sustainability Statement covers Kemira's value chain from upstream to downstream in full. Metrics, identified under topical standards, cover Kemira's own operations, unless otherwise specified.
BAM: The scope of the consolidation in the sustainability statement is the same as for the financial statements, including BAM’s subsidiaries (refer to page 198 of the financial statements). The subsidiaries are exempted from individual or consolidated reporting pursuant to Articles 19a(9) or 29a(8) of Directive 2013/34/EU. In addition, BAM applies the ESRS to define the organisational boundary for reporting sustainability information.
Heineken: The scope of entities included in the sustainability statements is equivalent to the consolidated entities included in the financial statements and in addition, relevant upstream and downstream elements of the value chain.
Airbus: The consolidation scope is aligned with the scope of the consolidated financial statements of the Company. When an information relates to a different perimeter - e.g. when the consolidation perimeter for a given metric differs -, the specificities are laid out in the respective section of this report. This sustainability statement covers the Company’s own operations, upstream value chain and downstream business relationships related to the direct use of its products. The double materiality assessment has been performed on the basis of this value chain. When relevant, details about specific scopes for certain policies, actions, metrics or targets can be found in connection with the information it concerns.
ISS World: The sustainability statement is consolidated following the Group’s accounting policies disclosed in its consolidated financial statements, unless otherwise specified in the accounting policies within each topical ESRS disclosure. We have defined operational control in accordance with the ESRS. In the event of acquisitions or divestments, the sustainability statement is following the same principles as the financial statements.
Sartorious Group: The scope of consolidation of the Statement is the same as the scope of consolidation of the consolidated financial statements as at December 31, 2024. In addition to the company’s own business operations, the double materiality assessment that was performed covered both its upstream and downstream value chain. The policies, actions, targets and data relate only to the consolidated companies’ own operations, unless otherwise stated.

Omitted Information / Use of Exemptions

BAM: Uses phased in requirements:

Heineken: ESRS 1 allows companies to not yet incorporate the value chain impact for certain metrics. We have made use of this exemption, by not including the impact of non-consolidated joint ventures and associates in our sustainability statements. HEINEKEN does not have control over these entities, and will assess in the coming years how to incorporate these entities in its sustainability statements. In addition, we applied the value chain exemption for a quantitative disclosure on post-consumer packaging waste, refer to section ‘Resource use and circularity - metrics’ for further information. For certain metrics, HEINEKEN makes use of the option to phase in the disclosures. The phase-in period varies from one year up to three years, depending on the metric. Where we applied a phase-in allowance, this is included in Appendix 5 (Reference table). For metrics that were reported in our 2023 Sustainability Review, we disclose the comparatives. For metrics that have not been reported previously, we apply the exemption to not report any comparatives. HEINEKEN, being based in an EU member state that permits the exemption from disclosure of impending developments or matters in the course of negotiation, has not utilised this provision.
Airbus: The Company has omitted certain information, in accordance with the Corporate Sustainability Reporting Directive's article on permitted omissions of seriously prejudicial information (CSRD, article 19a) as well as the section on intellectual property or results of innovation (ESRS 1, section 7.7). This article is included in the latest draft law transposing the CSRD in the Netherlands, where the Company is incorporated. For the sake of clarity this comes in addition to certain datapoints that may have been omitted as deemed not material information about topic management in view of the actual impact/risk/opportunity (IRO) boundaries (materiality of information, see ESRS 2 “– 6.1.4.2 IRO-2: Disclosure requirements in ESRS covered by the undertaking’s sustainability statement”).
ISS World: We have not omitted classified or sensitive material information nor any material information on grounds that it constitutes intellectual property, know-how or the results of innovation. We have made use of phase-in options for S1-11, S1-15 and E1-9.

Sources of Estimation:

Kemira: Sources of estimation and outcome uncertainty: When preparing the Sustainability Statement in accordance with ESRS, management is required to make estimates and assumptions on the metrics. As a basis for calculation and preparation of the sustainability metrics Kemira applies quality controls to ensure data completeness. Sustainability data collection includes direct measurements, calculations and estimations. Estimates and assumptions are continuously evaluated and are based on past experience and an expectation of future events that may have material implications and are considered to be reasonable under the circumstances. Sources of estimation and outcome uncertainty are described in the reporting principles of each section.
BAM: Estimations, sources of estimation, and outcome uncertainty: Making judgements, assumptions and estimates is a fundamental part of preparing sustainabilityrelated disclosures. Useful contextual assumptions and those that can significantly impact measurements are explicitly disclosed in the sustainability statement to aid in the interpretation of sustainability information.
Heineken: Certain metrics reported in our sustainability statements include third-party information and/or are subject to judgements, estimates and assumptions. When available, we make use of general well-known and reliable external sources and historical experience to arrive at reasonable and fair judgements, estimates and assumptions. Judgements, estimates and assumptions are regularly reviewed and updated. At the same time, we acknowledge that the use of third-party information and the aforementioned techniques implicitly bear the risk of outcome uncertainty. Given that the CSRD and the ESRS do not provide specific requirements on the validation process of third-party data, our current data validation process is based on high-level assessments and available guidance. We relied on actual data and in limited cases, where such information was not complete, we made use of assumptions and estimates. Our use of estimates is most significant for environmental metrics, such as Scope 3 greenhouse gas (GHG) emissions. Where we have used third-party information, estimates, judgements and/or assumptions, this is included in Appendix 4 (Basis of preparation) for the respective metric.
Airbus: In some circumstances when information is not available for a certain scope or for certain quantitative metrics, including monetary amounts, the Company uses estimates or proxies it considers relevant to provide a representation of a given topic. Such assumptions are presented in connection to the concerned information (in methodological notes for instance) with the objective to enable the reader to get a fair appreciation of the degree of uncertainty that would result from their use.
Sartorious Group: Publishes a useful table that goes into sources of estimation of specific data points.