So you would like to create a Code declaration for your company? The following five steps explain the process from prep to publication.
First things first, you need official approval from management. Next, choose the right people to form a team that accurately reflects the different areas of your company’s business. The team should include the topic experts and relevant managers from the various departments. Including your colleagues early on in the process will add extra weight and relevance to the issue.
Before you get started, you need to have a solid overview of the Code’s requirements. Certain aspects of the Code build on one another, and starting with a good overview can reduce the time needed to prepare your Code declaration. Clarify internally whether upstream processes are needed for reporting, for example setting up a working group, conducting a materiality analysis or establishing a shared understanding of sustainability. Check in advance whether you want to make use of external support, e.g. from the Code’s training partners.
Establish which information required by the Code you already have. For an overview of the criteria, aspects and performance indicators, please see our Sustainability Code checklist (German only). You can download a template for compiling report content from the download area of your company’s account on the Code database. As well as this general guide, we also provide a number of sector-specific guides (German only) to the Code.
Content and gathering of information
Decide which set of indicators (GRI or EFFAS) best suits your company. Be clear about what additional reporting content you want to integrate or are legally obligated to report (as per the CSR Directive Implementation Act, NAP Business and Human Rights, and/or the EU taxonomy).
Clarify which data your company currently has available and decide accordingly where you can report (comply) and where you can explain why no data is (yet) available (explain).
Identify departments or stakeholders (e.g. controlling, HR management, compliance, environmental management) that can contribute sustainability information. We advise contacting these stakeholders early on in the process, informing them about the process of compiling the Code declaration and, where necessary, securing their further involvement in the process. Should you decide to set up a working group, experience has shown that a mixed group with representatives from all relevant departments/business units is most effective.
Draw up a timeline for compiling your Code declaration. Companies that are obligated to report in accordance with the CSR Directive Implementation Act and the EU taxonomy should include the executive board, internal auditing and supervisory board in this timeline. If there is not yet a reporting routine in place, make sure you plan enough time to familiarise yourself with the process and enable decision-making cycles with other stakeholders.
Your profile on the database
Register on the Code database. Create a separate declaration of conformity for each reporting year. Select your chosen settings for the current year under review under “General information” (indicator set, CSR Directive Implementation Act if applicable, EU taxonomy if applicable, NAP Business and Human Rights if applicable).
In the download area, you can download a template tailored to your chosen settings. This way, the structure of your Code declaration can be taken into account when compiling the content of the report.
Use the “Assigned accounts” button to create accounts for other people involved in preparing the declaration (e.g. colleagues or also external consultancies).
You may refer to external documents in your declaration. However, for companies subject to reporting requirements, the extent to which this option applies is limited. In accordance with the CSR Directive Implementation Act, non-financial statements must take the form of a self-contained document, i.e. all relevant information must be described directly under the respective criteria.
The database includes the option to format text sections individually and to insert tables and graphics. We recommend that you always format any texts on the database first, because transfer errors often occur in copying text from Word documents and fonts and sizes may no longer correspond to the original Word formatting.
The heading “News from the Sustainability Code Office” on the database offers up-to-date information on relevant developments, events and support services.
“Guidance and contact” has links to helpful tools and offers the option to contact the Code team directly.
The Sustainability Code database, in particular the comparison feature, can also be a useful source of inspiration for your own sustainability management with ideas from other Sustainability Code declarations.
Creating your content
Now you can write the texts for your Code declaration. Use the criteria as the basis for your short reports and the performance indicators for your quantitative statements. You can provide information on core reporting parameters, for example reporting scopes, underlying assumptions and definitions used in the Code, under “General information”.
You must either report on the content requested (comply) or provide factual evidence as to why you are not (yet) able to give information on specific aspects (explain). The Sustainability Code sees sustainability as a process. As such, it is understandable if you are not able to report on all criteria in full for your first report. Where you still need to put effective processes in place for a topic, link your explanatory statement directly with a target date by when you want to comply. Since the Code applies to all companies and organisations, regardless of sector or size, it may well be the case that not every aspect is of equal relevance to every user company. This is where the materiality principle for reporting comes into play.
In order to focus the reader’s attention on the core content, report contents should be kept as long as necessary and as short as possible. We recommend a text length of between 500 and 3,000 characters per criterion.
For internationally active organisations, it may make sense to submit an English version of the Code declaration once the German original has been approved. The Sustainability Code team checks these translations at random and they are approved in the same way as the German version.
Tip: To create a text version, use a template from the download area once you have registered.
Support for the GRI SRS indicator set...
...is available from the Global Reporting Initiative directly on its website, where you will find information on data collection for each of the indicators in the corresponding documents. Should you need clarification on any of the terms used in the indicators, you can find a GRI glossary in each of the documents.
The EFFAS indicators...
...can be found in a document directly on the website of the European Federation of Financial Analysts Society.
Save or transfer your texts to the Code database. You can view whether all fields have been filled in under the option “Status of your profile”, where you will also find the “Submit” button. Once you have submitted your declaration, the Sustainability Code team will be automatically notified. They will then carry out a check for formal completeness. It is not possible for you to edit your texts during this process.
Review and feedback
You will receive your first round of feedback from the Sustainability Code Office within three weeks of submitting your declaration of conformity – further feedback may follow. You will receive an email informing you that your review has been completed. You can then view our feedback directly on the database. Please note, the Sustainability Code Office does not evaluate the content itself, provide advice or check the legal conformity of the submitted text sections as part of its formal completeness review.
Please edit all aspects marked in red (“missing”) in the status overview. If you require further information, please click “Details” to view any comments from the Sustainability Code team. We recommend you plan for at least one feedback loop in your timeline. Any changes you make to your texts following feedback will automatically be displayed to the Sustainability Code team on the database when you resubmit. Therefore there is no need to mark your additions and/or edits in your texts.
Information for companies subject to reporting requirements
Data, for instance consumption figures, training days or other personnel parameters, which is not yet available at the time of submitting the Code declaration can also be submitted later in the process. This can take the time-pressure off companies subject to reporting requirements, as the Sustainability Code team can get on with the review process for the submitted texts. The declaration of conformity should not be submitted to the supervisory board until it has been approved by the Sustainability Code team, as additional changes may still be necessary up until the declaration has been officially approved. Any changes requested by the supervisory board may be made subsequently, provided they still comply with the formal requirements of the Sustainability Code.
Involving third-parties in the Code declaration review
Companies that involve auditors or environmental specialists in checking their declarations can also do so via the Sustainability Code database. We can activate review authorisation for third parties on the database accordingly to include any relevant external parties in the review process described above.
As soon as all the information is formally complete and all ticks in the status overview are green (either for “comply” or “explain”), you will receive approval from us to publish your declaration of conformity. Until publication, only you are able to view it. Only you can see whether specific parts of the report have been reviewed as “comply” or “explain” on the database, including once the Code declaration has been published.
It is up to you whether you wish to publish your declaration on the Sustainability Code database yourself on receipt of our approval, or whether you would prefer us to publish it directly following the final review. Select an option using the corresponding database setting under “Status of your profile”. Once it is published, you will receive the Sustainability Code user signet. Please note, however, that the German Sustainability Code is not a form of certification.
Users report wanting to share the successful publication of their declaration on their own websites, on social media and in press releases as well as in sustainability or annual reports. Many companies also prepare compact sustainability brochures or easy-to-use infographics for their customers and/or suppliers on the basis of the declaration. We also recommend communicating the publication within your company, for example in staff magazines, on the company intranet or at team meetings. This way, you can raise further awareness among your employees and boost motivation.
Navigating sustainability management
Experience has shown that many user companies also leverage their declaration as a tool for reflecting on their own sustainability management. The Code declaration can help, for example, to systematically evaluate in-house goals and measures or to identify relevant topics for the future. The comparison feature on the Code database, in particular, may prove useful as an ever-growing pool of information on corporate sustainability performance and a source of inspiration.
Competitions & awards
Sustainability Code users are welcome to use their published declaration of conformity as part of their application for the German Sustainability Award (GSA). The GSA is awarded annually to companies of various sizes, among other organisations. Using the declaration shortens the application process by removing the questionnaire that would otherwise have to be filled in. Similarly, the application process for the German government’s CSR Prize references the respective Code criteria in a questionnaire, allowing you to simply recycle parts of the text.
External use of data
External parties do use the Code declarations of conformity, e.g. universities and research institutions for their own studies, financial market players to assess corporate sustainability performance and the future viability of business models, or non-governmental organisations to gain an informed insight into corporate processes. The Code team also analyses selected topic blocks at regular intervals in order to formulate review advice for users, to improve their own processes and to take the findings into the political debate.
We would like to draw the attention of users wishing to follow up their Code-based CSR reporting with a sustainability rating to the joint Sustainability Code and EcoVadis guide (German only). There is a great deal of overlap in terms of the CSR topics covered between the Code as a reporting 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.
Interested parties as well as those already using the Code will also find the step from or to the EMAS environmental management system easier. To this end, the German EMAS advisory board (UGA) published an updated study in 2021: Study on the interface between EMAS and the German Sustainability Code (German only). This was followed in 2022 by the „EMAS and the German Sustainability Code“ guidelines (German only). If you have already published a Code declaration, see here for information on how EMAS can be used to improve data quality and anchor further improvement processes in the company as a matter of course.
Here you can find further information about reporting.
All clear on the process? Next, we explain what goes into a Code declaration: qualitative criteria with various aspects and quantitative performance indicators.Learn more
Are you or will you be subject to reporting requirements? We can walk you through which reporting obligations you can meet with the Code.Learn more