EFRAG’s Value Chain Implementation Guidance should properly reflect existing exemptions for certain investment activities
News · 02-02-2024
The relevance of value chain disclosures triggered by ‘business relationships’ is generally evident. However, the Corporate Sustainability Reporting Directive (CSRD), the upcoming Corporate Sustainability Due Diligence Directive (CSDDD) and the Sustainable Finance Disclosure Regulation (SFDR) already make valid exemptions in specific cases of ‘business relationships’ resulting from financial assets like loans and equity investments. These exemptions concern investments in alternative investment funds (AIFs), Undertakings for Collective Investment in Transferable Securities (UCITS) and investments managed under individual discretionary portfolio management agreements. In today submitted comment letter, Eumedion asserts that EFRAG’s Value Chain Implementation Guidance should incorporate these exemptions and thereby safeguard consistency between CSRD, CSDDD and SFDR requirements.