| i. Governance structure for | Governance structure: | The governance structure for the plan in accordance with section 6.2.1, section 6.2.2. and section 6.5. | # Roles and responsibili-ties of the management body, any sub-committee | # Frequency of board meetings dedicated to the plan # Delays in approval of Qualitative: the plan Table 1 | |
| the plans including roles and re-sponsibilities for the formula-tion, validation, implementation, monitoring and updating of the plan, including escalation steps in case of deviation from targets. | Deviation and escalation procedure: | Governance arrangements for decision-taking on remedial actions in case of significant deviations in line with para-graphs 80 and 89. The capacity and resources re- | and three lines of defence # Escalation protocol that defines the process for ad-dressing deviations, in-cluding who should be no-tified and the steps to be taken. # Training and develop- | # Number of internal (e) (g) (h) audits conducted on (q) the plan Table 2 # Percentage of audit (d) (f) recommendations im- Table 3 plemented (a) # Number of escala-tions processed and/or unresolved escalations # ESG risks-related training completion | ESRS 2 GOV-1 _AR 4 |
| ii. Capacity and resources-re-lated actions to ensure appropri-ate knowledge, skills and exper-tise for effective implementation of the plan, including ESG risk-related trainings and internal culture. | Capacity and resources: | lated actions for the effective execution of the plan, based on an initial assessment by the institution of the potential gaps and needs as regards in-ternal culture and capabilities for ESG risks in line with sec-tion 5.4. This pertains to how the insti- | ment programs for ESG risks # Hiring and recruitment plans # Knowledge sharing and collaboration platforms # Leadership commitment # Qualitative description | rate # Identified gaps in ESG risk-related skills and Qualitative: knowledge Table 1 # Frequency and qual- (f) (m) ity of internal commu-nications regarding ESG risk-related objec-tives and progress # Metrics used to em-Qualitative: bed the risk appetite | ESRS 2-GOV-1 - para 23 ESRS G1 GOV-1 - para 5b |
| iii. Remuneration policies and practices to promote sound management of ESG risks in line with the institution’s objectives and risk appetite. | Remuneration policies and practices: | tution takes into account its risk appetite in relation to ESG risks as part of its remunera-tion policies and practices in line with Article 74(1)e of CRD. This pertains to the data and systems used for the formula- | of how remuneration pol-icies and practices have been, are or will be ad-justed to align with the overarching strategic ob-jective to address ESG risks and with the risk ap-petite # Data inventory with an identification of all rele-vant ESG risk data points | Table 1 related to ESG risks in (i) remuneration policies Table 2 # Proportion of staff (g) with ESG risk-related Table 3 metrics included in re-(a) muneration # Weighting of ESG-risk related metrics in the overall remuneration # Percentage of rele-vant data points col-lected and available Qualitative: | ESRS 2-GOV-2 - para 29 ESRS-E1-GOV-3 51 ESRS 1 Appen-dix B ESRS 2 AR 2 ESRS 2 SBM- |
| iii. Data and systems used for the transition planning process | Data and sys-tems: | tion, implementation and monitoring of plans in accord-ance with section 4.2.2 and paragraph 93. | and assessment of their availability and quality # Policies and procedures to ensure data quality | Table 1 # Percentage of sys- (p) tems and processes that integrate ESG data | 1_42a ESRS-E2-4_30c ESRS-S1-6_50d ESRS-S1-7_55b |