Firstly, companies that are categorised as both ‘public interest entities’ and ‘large’ and that have more than 500 employees must prepare and publish a ‘non-financial statement’. That statement relates, at a minimum, to environmental, social and employee matters, respect for human rights, and anti-corruption and bribery matters. Where a company does not pursue policies in any of these areas, it must give an explanation as to why not.
A ‘public interest entity’ is an entity, for example, that is a bank, an insurance undertaking, or a company listed on an EU regulated market.
The non-financial statement must be provided either as part of the annual directors’ report or as a separate statement. Where it is provided as a separate statement, it must be filed in the Companies Registration Office with the company’s annual return, or published on the company’s website.
The second reporting obligation is on companies that are listed on an EU regulated market and that are categorised as ‘large’. These companies must provide a description of the diversity policy they apply in respect of their board of directors (referred to as ‘diversity report’). This information forms part of the corporate governance statement that listed companies prepare. The diversity policy addresses factors such as the age, gender, and educational and professional background of directors. Where the company does not have a diversity policy, it must give an explanation as to why not.