Groupe Bruxelles Lambert

Since the Corporate Sustainability Reporting Directive (CSRD) came into force in January 2023, a large number of companies both within and outside the EU, have been required to report on sustainability. Some early adopters have already found themselves reaping the rewards. François Perrin, Head of ESG at Groupe Bruxelles Lambert (GBL), shares his company’s experience with the standards, the challenges and benefits, and offers some advice for other European private companies embarking on their CSRD journey.

Preparation efforts

“At GBL, we believe that non‑financial disclosure under commonly accepted international frameworks supports efficient capital allocation.

“Beyond compliance with relevant local and European regulatory requirements for non‑financial disclosure, GBL committed in 2021 to producing transparent non‑financial information at the holding level. This commitment is underpinned by our ESG policy and follows the Global Reporting Initiative (GRI) Standards Core option, the Sustainability Accounting Standards Board (SASB) standards and the Task Force on Climate‑related Financial Disclosures (TCFD) requirements. GBL has also been reporting through CDP since 2021; and from 2022 onwards, key ESG KPIs are covered by a reasonable assurance statement from GBL’s statutory auditors.

“Under supervision from GBL’s Board of Directors, and with support from the General Secretary and Finance team, the ESG department began preparing for the CSRD in 2023. This involved analyzing the content of the developing regulation, identifying potential best practices and forming a view on disclosures for an investment holding company under this new framework.”

Challenges and benefits of CSRD compliance

GBL found that CSRD implementation can present significant challenges for an investment holding company.

• The reporting scope based on the consolidated financial reporting perimeter can be at odds with the economic reality of an investment holding’s portfolio.

• There is a lack of industry-specific European Sustainability Reporting Standards (ESRS) covering financial and portfolio activities – a multi-year exercise that EFRAG, the European standard-setter, is currently undertaking.

• Increased sustainability disclosures in the annual report challenge the focus on value creation in financial communication.

• Limited assurance requirements imposed by the CSRD are leading to a gold-plated approach by audit firms.

• Pressure is put on ESG resources for other ESG-related tasks.

GBL set out a roadmap for navigating the CSRD, delivering on its reporting obligations and supporting its portfolio companies.

“In early 2024, upon finalizing GBL’s CSRD roadmap, the group’s Board of Directors and Audit Committee, as well as the governance entities of the portfolio companies directly in the scope of GBL’s reporting obligations, were briefed. To ensure compliance with the CSRD, key resource allocation decisions were made.”

Strategic advisors for GBL and its portfolio companies were selected in Q1 2024. GBL’s statutory auditors for the limited assurance of sustainability disclosures were appointed at the group’s General Meeting in May 2024, and the CSRD reporting service provider was confirmed in June 2024.

“To ensure CSRD compliance across its portfolio companies, GBL has been actively supporting its CSRD journeys since 2023. This includes invitations to GBL ESG Day — with the participation of EFRAG’s Vice-Chair, validation of CSRD roadmaps by the Board of Directors and Audit Committees, and ongoing supervision of implementation progress via weekly calls. As part of these efforts, GBL and its controlled entities invested more than €2m in 2024 (excluding full-time employee-related costs).

"In the last 12 months, CSRD implementation across GBL’s private companies has significantly accelerated their progress on their sustainability journeys. This progress has supported their brand recognition, access to financing, and value creation initiatives.

"Over the medium term, this first-mover advantage — along with sound sustainability impact, risk & opportunity management and mitigation — strengthens the companies’ valuation. It is therefore important to look beyond the compliance exercise and appreciate the business transformation opportunities resulting from more robust reporting processes and data. “

Recommendations

To the many European private corporates about to embark on their CSRD journeys, GBL offers the following advice:

1. Define your CSRD roadmap with support from your Board of Directors and Audit Committee as early as possible and ensure regular progress updates;

2. Stay true to your DNA and business model, ensuring that the CSRD compliance exercise supports your transformation rather than solely satisfying compliance and audit requirements; and

3. Consider disclosure through CDP to gain insightful knowledge and experience on ESRS requirements.

Explore the high degree of commonality between the CDP questionnaire and the ESRS E1 in the CDP-EFRAG mapping.