Five steps to a declaration of conformity with the Sustainability Code

To comply with the Sustainability Code, companies prepare a so-called declaration of conformity with the 20 Code criteria and the chosen quantifiable performance indicators. The following five steps explain the process all the way through to publication.

First, you need official approval from the management. Then select people with whom to form a team that accurately reflects the various areas of your company’s business. The team should include persons with specialist knowledge and responsibility from the various business units. Including your co-workers at this early stage will give the issue additional force and relevance.
Clarify whether you intend to also use the Sustainability Code to report in line with the CSR Directive Implementation Act and/or the National Action Plan for Business and Human Rights.

Review together with the team all 20 of the Sustainability Code criteria and the performance indicators. Determine for which criteria data is already available and, if necessary, where information is still lacking. If you have not yet formulated a strategy and/or policies, work together to identify which aspects of sustainability have key importance for your company to remain future-proof and what economic, environmental and social impact your business operations have. You can do this on the basis of a materiality analysis, for example. You can use the questions assigned to the Code criteria for guidance. By including the perspective of your stakeholders (e.g. customers, suppliers, employees), you will create a broader basis for the reporting process. Finally, determine within the team who is responsible for which criteria and by when data and texts need to be supplied.

If you also plan to use the Sustainability Code to report in line with the CSR Directive Implementation Act or the National Action Plan for Business and Human Rights, incorporate the additional questions and aspects into your data.
 

Consolidate all the quantitative and qualitative information available for the respective criteria. Formulate and describe the performance indicators you will be using for guidance and to evaluate goal achievement. No performance indicators have been developed specifically for the Sustainability Code. Instead, it draws on globally accepted reporting standards. Decide whether you will be using the indicators of the Global Reporting Initiative (GRI SRS) or the European Federation of Financial Analysts Societies (EFFAS KPIs for ESG) as your basis. Prepare an explanatory text (orientation: 500 to 3,000 characters per criterion) for each of the criteria of the declaration of conformity.

In these texts, you will report comprehensively on the relevant aspects (“comply”) or will outline why data or policies are not presented (“explain”). Tip: For drafting the texts, you can use the template available online in the download area following registration (step 4). Once drafted, have the texts and data approved by executive management. The brochure “The Sustainability Code: benchmarking sustainable business” and the guideline may also be of assistance. Sector-specific guidelines have been published for the waste management industry and municipal sanitation, the energy industry, the food industry, higher education institutions, medium-sized banks, savings banks and the housing industry.
In order to prepare a Code declaration of conformity in the database, you must first register as an administrator with a username and password. You will receive an email for the purpose of verifying your account. Once registration has been completed, you can begin creating your company profile in the Code database. You can edit it at any time, add additional users and create new reporting years.

Transfer all information collected thus far on the criteria (figures, texts and indicators) to the Code database. There is an input field for each criterion wherein you can edit your texts and figures. You can also add tables and images. Please note, however, that only the texts will be checked by the Code Office – not the images. You can check the status of your declaration under the “Status of your profile” tab. You can also ascertain whether your declaration is formally complete on the basis of the blue Help boxes to the right of each criterion. When you have completed all the input fields, submit your declaration to the Code team in the “Status of your profile” area (team(at)nachhaltigkeitskodex.org). Your declaration will be checked for formal completeness in line with the “comply” or “explain” requirements within two to three weeks on the basis of the aspects listed in the blue Help boxes for each of the criteria and indicators. If information is still missing, you will be given feedback in writing via the database. Following a successful review by the Code Office and with your approval, the Code declaration of conformity is then published in the database and your company is provided with the user signet for the corresponding reporting year.

Companies subject to the reporting obligation must obtain a corresponding audit from the supervisory board.
You can now use the declaration of conformity for your own corporate communications. Following the formal review by the Code Office, the Code signet can be included on your website, in brochures and in emails, among other things. You can issue a press release or inform your customers and/or commissioning partners and suppliers of the declaration of conformity personally. You can also export the Code declaration to other file formats, to serve as the basis for an integrated report, a sustainability report, a separate non-financial declaration or other means of communication.

We additionally encourage you to also submit your declaration in English. This is of interest in particular to companies with international business partners and also to make yourself visible at the European level in line with the EU’s obligation to report non-financial information. In so doing, you will be supporting the Council’s endeavours to position the Sustainability Code as a minimum standard in Europe. Simply upload your translated declaration to the database for the same reporting year and we will publish it as soon as we have performed a few spot checks.

For those users who wish to follow up their CSR reporting according to the Code framework with a rating, we would point out the joint Sustainability Code and EcoVadis guide. There is a lot of overlap in terms of the CSR topics covered between the Code as a transparency standard and an EcoVadis rating. This means there is little additional work involved for the users should a company wish to transition from reporting to active supply chain management or vice versa.
You can use the Code declaration of conformity to fulfil the CSR reporting obligation and comply with the National Action Plan for Business and Human Rights. To do so, when creating a new reporting year in the Code database, select either “Check according to CSR reporting obligation” and/or “Check according to NAP” under “General information”. You can then provide further information on the legally stipulated matters. These are likewise checked for formal completeness by the Code Office. Once approved by your management board and the Code Office, you can download the declaration and publish it on your website.

CSR reporting obligation

The Code declaration of conformity can serve as a non-financial declaration in order to comply with the CSR reporting obligation. Users therefor report in criterion 11, 14, 17, 18 and 20 , das DNK the Sustainability Code Office checks for formal completeness.

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NAP Business and Human Rights

The Code declaration of conformity can be used to report the core elements of the human rights due diligence obligations as per the National Action Plan for Business and Human Rights. Users therefor report in criterion 17, the Sustainability Code Office checks for formal completeness.

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Documents

You can download Council publications as PDF files and order certain brochures as hard copies free of charge. More information

Support

Learn more about the support services of the Sustainability Code Office, the training partners and the mentors. More information

Benefits of the Code

The Code provides support with implementing reporting, establishes a foundational set of data and makes the data available for further analysis. More information