CORPORATE GOVERNANCE AND FINANCE DEPARTMENT

NOTICE

MEMORANDUM

TO : ALL CONCERNED CORPORATIONS

SUBJECT : REQUEST FOR COMMENTS ON THE DRAFT MEMORANDUM

CIRCULAR ON THE REVISED SUSTAINABILITY REPORTING
GUIDELINES FOR PUBLICLY LISTED COMPANIES AND THE SEC
SUSTAINABILITY REPORTING FORM (SURE FORM)

DATE : 04 OCTOBER 2023

X -----------------------------------------------------------------------------------------------------------X

The Commission hereby requests comments and/or inputs on the attached

draft Memorandum Circular on the Revised Sustainability Reporting Guidelines for
Publicly Listed Companies and the SEC Sustainability Reporting Form (SuRe Form).

The written comments on the exposure draft must be submitted to the

Corporate Governance and Finance Department (CGFD) via email at
[email protected] on or before 16 October 2023.

Issued on 04 October 2023.

COMMENTS ON THE DRAFT MEMORANDUM CIRCULAR ON THE REVISED SUSTAINABILITY REPORTING
GUIDELINES FOR PUBLICLY-LISTED COMPANIES AND THE SEC SUSTAINABILITY REPORTING FORM
(SuRe FORM)

Name: ______________________________
Company: __________________________

Provisions on the Draft Comments Proposed Revision

Memorandum Circular/SuRe
Form
For example:
SuRe Form Additional Reminders What if our company failed to The provision must state that it is
indicate “0” or “N/A” in parts mandatory to indicate “O” or “N/A”
where disclosure is not in parts where disclosure is not
applicable, is there a applicable, otherwise the submission
corresponding penalty? shall be deemed incomplete or
invalid.

/zjca
Draft as of 04 October 2023

SEC MEMORANDUM CIRCULAR NO. ___

Series of 2023

TO : PUBLICLY-LISTED COMPANIES

SUBJECT : REVISED SUSTAINABILITY REPORTING GUIDELINES FOR

PUBLICLY-LISTED COMPANIES

WHEREAS, the Commission plays an active role in promoting sustainability reporting in the
Philippines through the issuance of SEC Memorandum Circular (MC) No. 4, Series of 2019, also known
as the Sustainability Reporting Guidelines for Publicly-Listed Companies (PLCs) or the SR Guidelines,
which mandated sustainability reporting in the Philippines under a “comply or explain”
approach or that which allowed PLCs to disclose corporate sustainability data, when
available, and provide explanations for items where data is unavailable;

WHEREAS, on 26 June 2023, the International Sustainability Standards Board (ISSB)

issued its inaugural standards, the International Financial Reporting Standards (IFRS) S1 (General
Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-
related Disclosures), which create a common language for disclosing the effects of climate-
related risks and opportunities on a company’s prospects, and ensure that companies
provide sustainability-related information alongside financial statements, in the same
reporting package1;

WHEREAS, in the exercise of its rule-making powers, the Commission recognizes and
integrates the latest developments in global sustainability reporting frameworks, including the IFRS
S1 and IFRS S2—both of which fully incorporate the recommendations of the Task Force on Climate-
related Financial Disclosures (TCFD)— the United Nations Sustainable Development Goals (UN
SDGs), Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB),
International Integrated Reporting Council (IIRC), and the United Nations Conference on Trade and
Development (UNCTAD) - International Standards of Accounting and Reporting (ISAR) Guidance on
Core Indicators, among others; and

WHEREAS, Section 179 (d) of Republic Act No. 11232, otherwise known as the Revised
Corporation Code of the Philippines, grants the Commission the power to promote corporate
governance and the protection of minority investors, through, among others, the issuance of rules and
regulations consistent with international best practices;

1 https://www.ifrs.org/news-and-events/news/2023/06/issb-issues-ifrs-s1-ifrs-s2/
 NOW, THEREFORE, to further promote sustainability reporting, make the same relevant and
useful for Philippine PLCs, and contribute to a robust sustainability reporting framework in the
country, the Commission, in its En Banc meeting on 28 October 2023, resolved to issue the Revised
Sustainability Reporting Guidelines for Publicly-Listed Companies (Revised SR Guidelines) attached
to this Memorandum Circular.

Sustainable practices are shown to lead to company benefits like improved management
systems, a motivated workforce, and sustainable vision, strategy, and business plans. Moreover, the
Revised SR Guidelines serves as an effective tool to encourage companies to adopt sustainable business
practices and attract Environmental, Social, and Governance (ESG) investors in the country’s capital
markets.

The Revised SR Guidelines is intended to help PLCs assess and manage non-financial
performance across Economic, Environmental, and Social aspects of their organization, and enable
PLCs to measure and monitor their contributions towards achieving universal targets of sustainability,
such as the United Nations Sustainable Development Goals, as well as national policies and programs,
such as AmBisyon Natin 2040.

Section I. Sustainability Reporting Format

The Sustainability Reporting (SR) required of PLCs shall be composed of the following:

1. SR Narrative: The PLCs shall submit a narrative sustainability report. The SR Narrative
follows the format under SEC MC No. 4, Series of 2019. The SR Narrative shall be submitted
together with the company’s Annual Report (SEC Form 17-A). It is recommended to have a
one-page Executive Summary/ Highlights of the companies’ sustainability activities,
programs, and projects at the beginning of the report.

2. Sustainability Report (SuRe) Form: The PLCs shall submit their duly answered SuRe Form
through the SEC Electronic Filing and Submission Tool (eFAST), or any other related SEC-
approved/implemented submission tools for easier access, data capture, analytics, and data
management.

The SuRe Form SHALL be submitted in Microsoft Excel format.

The SuRe Form template includes three (3) major parts, to wit:

A. Sustainability and Climate-related Opportunities and Risks Exposures (SCORe);

B. Cross-Industry Standard Metrics (CISM); and
C. Industry-Specific Metrics (ISM).

The PLC MAY also attach its SuRe Form or the details of the Form at the end of the SR Narrative,
in addition to the eFAST submission.
 Section II. SuRe Form Submission Process – Mode of Submission

The SuRe Form shall be submitted to the Commission in Microsoft Excel file format, and shall
be done using eFAST through the link: ____________.

The PLCs must ensure that for the Microsoft Excel file, the fields are NOT moved, merged nor
altered when inputting data. Otherwise, the system will not accept the submission. Further
instructions for filing may be accessed on eFAST.

Note that neither signature nor notarization is required for both the SR Narrative and the
SuRe Form. However, it is the board's responsibility to confirm in writing in the SR Narrative that it
has reviewed the accuracy and completeness of the SR submissions.

The SEC will also post on the eFAST website and the official SEC website the step-by-step
guidelines on how to file the SuRe Form using the eFAST.

Section III. Deadline for submission of the SR

The SuRe Form is required to be submitted starting in the year 2024 covering the reporting
year 2023. The SuRe Form covering the reported year shall be submitted through eFAST on or before
April 15 of the following year during the same time as the filing of the PLCs Annual Report (SEC Form
17-A), which is within 105 calendar days from the end of the fiscal year.

The Narrative SR covering the reported year shall be attached as an Annex to the SEC Form 17-
A to be submitted in the following year.

Section IV. Disclosures under the SuRe Form

The SuRe Form shall be composed of mandatory disclosures, unless otherwise indicated.

Section V. SuRe Form Additional Reminders

• The companies must indicate “0” if the disclosure has zero (0) value and indicate “N/A” if the
disclosure is not applicable.
• Note that “0” and “N/A” are not interchangeable.
• The industry classification of the companies must be based on the 2019 Philippine Standard
Industrial Classification (PSIC).
• If the reporting PLC is a holding company, that PLC’s SR must not include subsidiaries that are also
listed. These listed subsidiaries are required to submit a separate and independent SR in
accordance with this MC.
 Section VI. Penalty for Failure to Timely Submit SuRe Form and/ or Narrative SR with the
Annual Report

Non-submission, non-attachment, or late submission of the SuRe Form and/ or Narrative SR

shall be subject to the following separate and distinct penalties:

Non-attachment of Non- Late submission4 Incomplete

SR Narrative2 submission of
SuRe Form3
First Reprimand/ Reprimand/ Reprimand/ Reprimand/
Offense Warning Warning Warning Warning
Second P50,000 + P500 per P50,000 + P500 P30,000 + P500 per P30,000 + P500
Offense day of delay per day of delay day of delay per day of delay in
completing the
SuRe Form
Third P100,000 + 1,000 per P100,000 + P60,000 + P1,000 P60,000 + P1,000
Offense day of delay 1,000 per day of per day of delay per day of delay in
delay completing the
SuRe Form
Fourth Suspension/ Suspension/ P500,000.00 + P500,000.00 +
Offense Revocation of Revocation of P2,000 per day of P2,000 per day of
Secondary license or Secondary delay delay in
a fine of license or a fine completing the
P1,000,000.00 of P1,000,000.00 SuRe Form

It must be emphasized that compliance with only one of the requirements (SR Narrative or
SuRe Form) does not amount to compliance with this Memorandum Circular. Thus, penalties for each
infraction listed above are cumulative.

2
The penalty will apply if the non-attachment is more than 30 calendar days from the due date.
3 The penalty will apply if the non-submission is more than 30 calendar days from the due date.
4 The penalty will apply for late submission of either the SR Narrative or the SuRe Form.
 Section VII. Transition Period for Compliance

In recognition of the critical need for a relief period for transition, PLCs may comply with
disclosures specified in this Memorandum Circular on a “comply or explain” basis for a period of two
(2) years. Afterwards, mandatory submission of ALL disclosures required by this Memorandum
Circular shall be mandatory and therefore, subject to penalties.

Section VIII. Modification/Amendment

All other circulars, memoranda, notices and implementing rules and regulations that may be
inconsistent with the foregoing provisions shall be deemed modified or amended accordingly.

Section IX. Effectivity

This Memorandum Circular shall take effect immediately upon its approval.

Makati City, Philippines, ____2023.

//mar
//ice
 Company name: Company ABC
Sustainability Report (SuRe) Form Email address of contact person: [email protected]
SUSTAINABILITY- AND CLIMATE-RELATED RISKS, OPPORTUNITIES & METRICS Reporting period: January 1 to December 31, 2023
PSIC Code: 64199
PSIC Section: Financial and Insurance Activities
Independent assurance level and provider: Limited assurance - 123 & Co.

Governance Disclosure Reference

1. Governance body
Describe your current governance processes, controls, policies, and procedures with regards to sustainability-related risks or opportunities, including climate-related risks or opportunities.
Name of the Board Committee or individual/s responsible for oversight of IFRS S1.27 a Disclosure, IFRS S2.6 a
sustainability-related risks or opportunities, including climate-related risks or Disclosure
opportunities (SRROs)
Key responsibilities of the identified Board Committee or individual/s, including: IFRS S1.27 a (i, v) Disclosure, IFRS S2.6 a
- whether responsibilities include oversight for the setting of targets related to (i,v) Disclosure
SRROs; and
- monitoring of progress towards those targets

Policies and procedures of the identified Board Committee or individual/s IFRS S1.27 a (ii, iii, iv) Disclosure, IFRS S2.6
including but not limited to: a (ii, iii, iv) Disclosure
- determining the availability of appropriate skills and competencies within the entity
to oversee strategies and respond to SRROs;
- determining the frequency of management reporting to the identified Board
Committee;
- monitoring of progress towards set targets;
- considering SRROs in making decisions as well as the associated trade-offs; and
- linking climate and sustainability-related risk performance to remuneration
policies

2. Role of management
Describe management's role, processes, controls, policies, and procedures with regards to SRROs.
Name and description of specific management-level committee or IFRS S1.27 b (i) Disclosure, IFRS S2.6 b (i)
management-level position assigned to monitor and manage SRROs Disclosure

Policies and procedures used by the specific management-level committee or IFRS S1.27 b (ii) Disclosure, IFRS S2.6 b (ii)
management-level position to integrate the monitoring and management of Disclosure
SRROs with other internal functions

Strategy Disclosure Reference

3. Material climate- and sustainability-related risks and impact on the business model and value chain
Legend: Indicate the impact of the SRROs on your company's business model and value chain according to the guidance below.
• High - More than 30% of the enterprise asset value and/or revenue is exposed to and vulnerable to the climate hazards and sustainability risks
• Medium - Between 5 to 30% of the enterprise asset value and/or revenue is exposed to and vulnerable to the climate hazards and sustainability risks
• Low - Below 5% of the enterprise asset value and/or revenue is exposed to and vulnerable to the climate hazards and sustainability risks

Impact to Business Model (Enterprise-level) Impact to the Upstream and Downstream Value Chain IFRS S1.30 a, b, c Disclosure, IFRS S1.32 b
Current reporting Current reporting Disclosure, IFRS S2.10 a, b, c, d Disclosure,
Next reporting period Short-term Medium-term Long-term Next reporting period Short-term Medium-term Long-term IFRS S2.13 b Disclosure
Climate-related risks period period
(1-5 years) (6-15 years) (16 years and beyond) (1-5 years) (6-15 years) (16 years and beyond)
Physical hazards
Extreme winds / Tropical cyclones / Storms
Floods
Droughts
Extreme Heat
Landslides from extreme rainfall
Rising sea level
Others (please specify; add more rows as necessary)
Transition risks
Policy and legal risk: Increased pricing of GHG emissions
Policy and legal risk: Increased regulation of existing products and
services
Policy and legal risk: Exposure to sustainability-related litigation
Technology risk: Costs to transition to lower emissions technology
Market risk: Increased cost of raw materials
Reputational risk: Shifts in consumer preferences
Reputational risk: Stigmatization of sector/industry
Reputational risk: Increased stakeholder concern or negative
stakeholder feedback
Others (please specify; add more rows as necessary)
Other sustainability-related risks
Human capital
Labor and Human rights
 Nature & Biodiversity loss
Raw Materials Scarcity
Water scarcity
Others (please specify; add more rows as necessary)
Description of how the company's definition of the time horizons (short - to IFRS S1.30 c Disclosure, IFRS S2.10 d
long-term) is linked to your planning horizons for strategic decision-making Disclosure

4. Management of highly material climate- and sustainability-related risks

Based on your response to the previous question, use the table below to disclose and enumerate the climate- and sustainability-related risks that were identified as having "high" impact to the business model and value chain, and provide the required information per risk.
High risks Description of how the risk significantly affects the business model and/or value chain, Entity's response or risk mitigation and/or adaptation strategy, including progress against Resource allocation IFRS S1.32 b Disclosure, IFRS S1.33 a, b, c
High risk 1 Disclosure, IFRS S2.13 b Disclosure, IFRS S2.14
a (iv), b, c Disclosure
High risk 2
High risk 3
High risk 4
High risk 5
Other high risk (please specify; add more rows as necessary)
Overall Resilience of your Business IFRS S1.41 Disclosure
Provide discussion on the current level of resilience of the entities' strategy and IFRS S2.22 a Disclosure
business model in relation to the risks above
Contextual Information. Provide further information on the risk assessment IFRS S1.41 Disclosure
process you performed to generate the disclosure above, specifically: IFRS S2.22 a Disclosure
IFRS S2.22 b Disclosure
IFRS S2.22 b (i.2) Disclosure
- How and when climate-related scenario analysis was carried out; IFRS S2.22 b (i.3) Disclosure
- Whether climate-related scenario analysis included diverse range of climate- IFRS S2.22 b (i.4) Disclosure
related scenarios and what scenarios were considered;
- Whether climate-related scenarios used are associated with climate-related
transition risks, climate-related physical risks, or both; and
- Whether the climate-related scenario was used that is aligned with latest
international agreement on climate change.

5. Impact of material climate- and sustainability-related risks on the company's financial position, financial performance, and cash flows
Given your strategy, and wherever applicable, disclose the quantitative (single amount or range) or qualitative current and anticipated financial effects for each type or category of risk across the time horizons indicated below.
Current and Anticipated Financial Effects IFRS S1.35 a, b, c, d Disclosure, IFRS S1.40
Current reporting period Next reporting period Short-term Medium-term Long-term a, b Disclosure, IFRS S2.16 a, b, c, d
Climate-related risks
Disclosure, IFRS S2.21 a, b Disclosure
Physical risks • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Transition risks • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Other sustainability-related risks

Nature & Biodiversity loss • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Others (please specify; add more rows as necessary) • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

6. Climate- and sustainability-related opportunities

Wherever applicable, describe the key climate- and sustainability-related opportunities relevant to your company.
Opportunities Description of opportunities IFRS S1.35 a, b, c, d Disclosure, IFRS S1.40
a, b Disclosure, IFRS S2.16 a, b, c, d
Decarbonization & Resource Efficiency Opportunities
Disclosure, IFRS S2.21 a, b Disclosure
Use of more efficient modes of transport
Use of more efficient production and distribution processes
Use of recycled products, substitutes, or diversification
Move to more efficient buildings
Reduced water consumption
Use of lower-emission sources of energy
Use of supportive policy incentives
Participation in carbon market
 Disclosure, IFRS S2.21 a, b Disclosure

Shift toward decentralized energy generation

Products and services
Development and/or expansion of low emission goods and services
Development of climate adaptation and risk transfer solutions
Diversify into low-carbon business models
Markets
Improved competitiveness
Access to new assets and locations
Others (please specify; add more rows as necessary)
7. Impact of climate- and sustainability-related opportunities and its impact on the company's financial position, financial performance, and cash flows
Given your strategy, and wherever applicable, disclose the quantitative (single amount or range) or qualitative current and anticipated financial effects of your company's top climate- and sustainability-related opportunities across the time horizons indicated below.
Current and Anticipated Financial Effects IFRS S1.35 a, b, c, d Disclosure, IFRS S1.40
Current reporting period Next reporting period Short-term Medium-term Long-term a, b Disclosure, IFRS S2.16 a, b, c, d
Climate-related opportunities
Disclosure, IFRS S2.21 a, b Disclosure
Opportunity 1 • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Opportunity 2 • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Others (please specify; add more rows as necessary) • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Other sustainability-related opportunities

Others (please specify; add more rows as necessary) • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance: • Impact on financial performance:
- - - - -
• Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position: • Impact on financial position:
- - - - -
• Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows: • Impact on cash flows:
- - - - -

Risk Management Disclosure Reference

8. Risk management process
Describe your current processes, procedures, and practices with regards to the following activities.
Identification of climate- and sustainability-related risks, including whether IFRS S1.44 a (ii) Disclosure, IFRS S2.25 a (ii)
and how you used climate-related scenario analysis to identify climate- Disclosure
related risks
Assessment and prioritization of climate- and sustainability-related risks IFRS S1.44 a Disclosure, IFRS S2.25 a
Disclosure
Monitoring of climate- and sustainability-related risks IFRS S1.44 a Disclosure, IFRS S2.25 a
Disclosure
Changes in your processes to identify, assess, prioritize, and monitor these IFRS S1.44 a (vi) Disclosure, IFRS S2.25 a
risks compared with the prior reporting period (vi) Disclosure

9. Opportunity management process

Describe your current processes, procedures, and practices with regards to the following activities.
Processes to identify, assess, prioritize, and monitor climate- and IFRS S1.44 a (vi) Disclosure, IFRS S2.25 a
sustainability-related opportunities, including whether and how you used (vi), b Disclosure
climate-related scenario analysis to identify climate-related opportunities
10. Integration of risk and opportunity management process to overall/enterprise risk management
Describe your current process, procedures, and practices with regards to the following activities.
Extent to which and how processes for identifying, assessing, IFRS S1.44 c Disclosure, IFRS S2.25 c
prioritizing and monitoring SRROs are integrated into or inform entity's Disclosure
overall risk management process

Metrics and Targets Disclosure Reference

11. Metrics and targets for physical risks
 Metrics Method used to calculate and scope Sources from which metrics were drawn Base Period Performance Milestones & Target & Period over which the Third-party Validation
(Absolute or Intensity - IFRS S2.33 g Disclosure) Part of entity to which climate-related (IFRS S1.49 Disclosure) from which progress for climate-related (IFRS S1.51 f Disclosure, IFRS S2.35 climate-related target applies (IFRS S1.50 c Disclosure)
target applies target is measured Disclosure) (IFRS S1.51 c Disclosure, IFRS S2.33 d
(IFRS S2.33 c Disclosure IFRS S1.50 d (IFRS S1.51 d Disclosure, IFRS S2.33 e Disclosure)
Disclosure) Disclosure)
Intensity Metric: Exposure Assessment Coverage –Percentage of total
number (or asset value) of business-critical assets assessed for ___% by 20__ Yes/No
exposure to projected climate hazards
Intensity Metric: Vulnerability Assessment Coverage - Percentage of
the total number (or asset value) of business-critical assets assessed
for its vulnerability to material climate hazards.
Intensity Metric: Asset Resilience Percentage – Percentage of assets
(in number or asset value) assessed for exposure and vulnerability and
improved for its resilience to material hazards with minimal residual
risks.
Others (please specify; add more rows as necessary)
12. Metrics and targets for transition risks
Absolute Metric: Future GHG-related tax liabilities based on GHG
___% by 20__ Yes/No
emissions and benchmark carbon price.
Intensity Metric: Future GHG-related tax liabilities as a percent of total
taxes paid to government (based on GHG emissions and benchmark
carbon price)
Intensity Metric: Projected cost to transition to low-carbon operations.
Others (please specify; add more rows as necessary)
13. Metrics and targets for other sustainability risks
Living Wage Performance – Percentage of workers paid at least a living
___% by 20__ Yes/No
wage
Others (please specify; add more rows as necessary)
14. Contextual Disclosures(Provide elaboration on the context and assumptions relevant to the disclosures above. Distinguish the context between physical and transition risks as needed.)
Disclosure Reference
Entity's Objective and approach to setting and reviewing the climate- IFRS S1.50 a Disclosure
IFRS S2.34 Disclosure
related metrics, and target, and monitoring progress IFRS S2.33 b Disclosure
• Whether and how company-specific metrics were derived by adjusting IFRS S2.33 h Disclosure
metrics taken from source other than the IFRS Sustainability IFRS S2.29 f (i) Disclosure
Disclosure Standards IFRS S2.29 g (i) Disclosure
• Whether and how your climate-related target has been informed by
latest international agreement on climate change
• Whether and how the entity is applying a carbon price in decision-
making
• Whether and how climate-related considerations are factored into
executive remuneration
Redefinition or replacement of metrics, and targets (if any) including IFRS S1.51 g Disclosure, IFRS S2.34 d
Disclosure, IFRS S1.52 Disclosure, IFRS S1.B52
metrics used to set and monitor progress towards reaching entity's
Disclosure
targets.
Explanation of and reasons for changes in metric. IFRS S1.B52 b Disclosure, IFRS S1.B52 c
Disclosure

General Requirements Disclosure Reference

15. Source of guidance, reporting period, and statement of compliance
Sources of guidance the entity has applied in preparing sustainability- IFRS S1.59 a Disclosure
related financial disclosures IFRS S1.59 b Disclosure
Industry(s) applied in preparing sustainability-related financial disclosures

Date of start and end of reporting period IFRS S1.66 a Disclosure

If applicable, whether amounts disclosed in sustainability-related financial IFRS S1.66 b, c Disclosure
disclosures are not entirely comparable due to change in length of
reporting period
Information about transactions, other events and conditions that IFRS S1.68 Disclosure
occur after end of reporting period, but before date on which
sustainability-related financial disclosures are authorized for issue
Entity's explicit and unreserved statement of compliance IFRS S1.72 Disclosure
16. Judgements, uncertainties and errors
Information about judgements, apart from those involving estimations of IFRS S1.74 Disclosure
amounts
Sources of measurement uncertainty and assumptions, IFRS S1.78 Disclosure
approximations and judgements entity has made in measuring amounts
that are subject to high level of measurement uncertainty
17. Application guidance
If applicable, type of material information not disclosed due to IFRS S1.B33 Disclosure
prohibition of disclosure and explanation of source of restriction
 If applicable, exemption used by the entity to omit information about IFRS S1.B36 a Disclosure
opportunity when information is commercially sensitive
Information about significant differences between data and IFRS S1.B42 c Disclosure
assumptions used in preparing the entity's sustainability-related financial
disclosures and related financial statements
18. Errors
If applicable, nature of errors in prior periods IFRS S1.B58 a Disclosure
If applicable, circumstances that led to existence of prior period IFRS S1.B58 c Disclosure
errors that are impracticable to correct, and description of how and from
when errors have been corrected

Legends:
Disclosure is mandatory.
Disclosure is encouraged.
 Company name: Company ABC
Sustainability Report (SuRe) Form Email address of contact person: [email protected]
SUSTAINABILITY- AND CLIMATE-RELATED RISKS, OPPORTUNITIES & METRICS Reporting period: January 1 to December 31, 2023
PSIC Code: 64199
PSIC Section: Financial and Insurance Activities
Independent assurance level and provider: Limited assurance - 123 & Co.

Information on Target/s
Category and Sustainability
Metric Unit of measure Data Disclosure Period over which the Reporting Standard
Disclosure Topic Target Base period Milestones/interim targets
target applies
Metrics and targets relevant to managing transition climate risks
Financial Metrics 1. Capital deployment Amount of capital expenditure, financing or investment IFRS S2.29 e Disclosure, IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f
deployed in million Php towards climate-related risks Disclosure
resilience
2. Internal carbon prices Price for each metric tonne of greenhouse gas emissions the IFRS S2.29 f (ii) Disclosure, IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d,
entity uses to assess the costs of its greenhouse gas e, f Disclosure
emissions
3. Remuneration linked to climate-related considerations Percentage of executive management remuneration IFRS S2.29 g (ii) Disclosure, IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d,
recognized in the current period that is linked to climate- e, f Disclosure
related considerations
GHG Emissions 4. Gross Scope 1 GHG emissions Metric tons CO2e IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
5. Gross location-based Scope 2 GHG emissions Metric tons CO2e IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
6. Gross Scope 3 GHG emissions Metric tons CO2e IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
7. GHG emissions intensity Metric tons CO2e per million Php revenue IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
Metrics and targets relevant to managing climate-related opportunities
Climate-related disclosures 8. Climate-related opportunities Amount in million Php and percentage of assets or business IFRS S2.29 d Disclosure, IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f
activities aligned with climate-related opportunities Disclosure
Metrics relevant to the management of all other sustainability-related risks and opportunities
Investments in sustainable 9. Total amount of investments on sustainable industries and Amount in million Php IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
activities or industries activities according to ASEAN Green Taxonomy/BSP's sustainable
finance taxonomy or UN SDGs
Energy management 10. Energy intensity GJ per million Php revenue IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
11. Total and percentage of renewable energy (RE) consumption Absolute number (in GJ) and % RE consumption over total IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
energy consumed
Water management 12. Water intensity Cubic meters per million Php revenue IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
13. Total and percentage of water recycled and reused Absolute number (in cu.m) and % water recycled and reused IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
over total water consumed
Waste management 14. Solid waste intensity Metric tons per million Php revenue IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
15. Total and percentage of waste recycled or reused Absolute number (in ton) and % waste recycled or reused IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
over total wastes generated
Diversity and inclusion 16. Total number of board of directors, by gender Headcount IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
17. Total number of employees, by gender Headcount IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
18. Total number of indirect hires, by gender Headcount IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
19. Total number of senior management employees, by gender Headcount IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
20. Total number of middle management employees, by gender Headcount IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
21. Total number of rank-and-file employees or staff, by gender Headcount IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
Employee wellbeing and 22. Number and percentage of employees coverage by collective Headcount and % of employees covered over total rank-and- IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
engagement bargaining agreement/s file employees
Data privacy and security 23. Number of incidents of data breaches Number of substantiated incidents IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
Other company-specific sustainability metrics
Topic (please specify; add rows as Company-specific metric (please specify; add rows if necessary) (unit of measure) IFRS S1.50 Disclosure
necessary)
Topic (please specify; add rows as Company-specific metric (please specify; add rows if necessary) (unit of measure) IFRS S1.50 Disclosure
necessary)
Topic (please specify; add rows as Company-specific metric (please specify; add rows if necessary) (unit of measure) IFRS S1.50 Disclosure
necessary)

Other qualitative metrics relevant to the management of all other sustainability-related risks and opportunities Descriptive Disclosure
Procurement 25. Policy on responsible/sustainable procurement practices Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
Net Zero commitment 26. Policy on SBTI net zero commitment Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
Employee wellbeing and 27. Additional employee benefits (on top of statutory benefits) List of additional benefits IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
engagement 28. Policy, strategy, or formal grievance process on gender-based Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
harassment and bullying in the workplace
29. Policy, strategy, or formal grievance process on the health, safety, Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
and wellbeing of employees in the workplace
30. Policy, strategy, or formal grievance process with regards to Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
employee decorum
Data privacy and security 31. Processes and procedures related to data privacy and security, Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
information security, or cybersecurity
Children's rights 32. Company policy (and practices) on children’s rights as Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
consumers, dependent of workers, or workers themselves.
33. Company policy or practices requiring commitment of suppliers Description or narrative IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
and/or contractors to respect children’s rights.
Contributions to UN SDGs 34. Summary (and estimated financial equivalent) of contributions to Description IFRS S1.51 a, b, c Disclosure, IFRS S2.33 d, e, f Disclosure
the company's focused or relevant UN SDGs

Legends:
Disclosure is mandatory.
Disclosure is encouraged.