Implementing Action

Back Corporate Social Responsibility reporting for large companies

Since legislation in 2009, large Danish companies have had a legal obligation report on Corporate Social Responsibility (CSR) reporting – also known as the comply-or-explain model. In 2015 the Danish Parliament revised the regulations due to the EU-directive on non-financial reporting.

From 1 January 2016 large companies in class C and D must report on their CSR activities.

Class D companies are listed companies and State owned enterprises.
Class C companies that exceeds at least two of the three size limits in two consequent years:

  • Balance sum of 156 million DKK
  • Revenue of 313 million DKK
  • An average number of 250 employees (full-time).

Subsidiaries are exempt from having to report on CSR if the parent company does so for the entire group.
The same reporting requirement has also been introduced for institutional investors, mutual funds and other listed financial businesses (financial institutions and insurance companies, etc.) not covered by the Danish Financial Statements Act. For these businesses, the requirement has been introduced in Executive Orders issued by the Danish Financial Supervisory Authority.

The companies that are covered by the statutory requirement have to state:

  1. A brief description of the company's business model.
  2. A description of the CSR policies pursued. At a minimum:
    • Environmental policies, including measures to reduce the climate impacts of the company's activities;
    • Social conditions and employee conditions;
    • Respect for human rights; and
    • Measures to fight bribery and corruption.
  3. For each policy area, it must be stated how the business puts its CSR policy into practice, and any systems or procedures in this respect must be described. Details must also be given of the due diligence processes applied, if the business uses such processes.
  4. Risks related to the business's activities of the company must be described and include details of how the company manages the risks in question. Information must be provided for each policy area.
  5. Details concerning the company’s of non-financial key performance indicators.
  6. Details describing the company’s assessment of achieved results of its CSR initiatives, and future expectations. Information must be provided for each policy area, see above.

Where the company does not pursue CSR policies, this must be disclosed.

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Denmark 2009
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