The Board of Directors has the ultimate responsibility over the Group’s Sustainability disclosures. Nonetheless, there are previous levels of authority in place to ensure consistency, integrity and robustness of ESG data disclosures. It is the case of the Audit Committee, which is responsible for, among others, monitoring the preparation and disclosure of both financial and non-financial information1. The Group’s CCGCR, as the specialised committee for sustainability issues, is also informed about the Group’s processes and actions to ensure alignment with the sustainability reporting frameworks such as the European Sustainability Reporting Standards as well as about the actions in place – and planned – to ensure reporting consistency, robustness and integrity. The Group’s Corporate Communications and Responsibility Functional Division, liable for the development, implementation and monitoring of its sustainability strategy, is also responsible for the processes established by the Company for collecting and processing data related to environmental and social sustainability. It is this division that is responsible for providing regular sustainability updates to the CCGCR, the Audit Committee and the Board of Directors.
Our sustainability reporting control systems follow an approach similar to the financial reporting control system although not yet at the same level of maturity as can be verified by the level of assurance of the external verification process: Limited Assurance for Sustainability disclosures and Reasonable Assurance for Financial disclosures. It is our aim to progressively work towards ensuring Sustainability assurance level matches Financial assurance levels.
As the sustainability reporting scope has been significantly increasing over the years – we currently verify over 240 ESG-related indicators to different sustainability frameworks –, we have established a wider range of internal controls to support identification and mitigation of the risks related to data accuracy and completeness. One example includes regular internal reporting of key indicators and metrics to measure progress throughout the year, and identifying relevant information gaps, inconsistencies or even needs of adapting data collection and consolidation to changes in the methodologies prescribed in the sustainability frameworks the Group uses to disclose sustainability data. This allows us to identify and address these issues on a regular basis. The collection of these indicators varies between every trimester, semester or annual basis and is done in cooperation with internal data owners within each of the Group’s Companies.
In 2024, we considered previous years’ ESG assurance processes and their recommendations, as well as observations from the Group’s Internal Audit Division, and identified the main risks that could directly or indirectly impact our sustainability statement: misstatement of information, operational errors and fraud. To mitigate these errors, we are implementing several actions as the application of a digital solution that will help address financial and ESG challenges in statutory reporting. This will enable greater data traceability, real-time mapping of received information, clear data ownership, completed and pending processes, among other benefits.
1 Information on the responsibilities of the Audit Committee is available in point 30. “Details of the Supervisory Board (Audit Committee) Representing the Model Adopted”.