“This CSRD project allows us to enrich our CSR roadmap”

EBRA employs 3500 people and has 9 press titles (Le Dauphiné Libéré, Le Progrès or L'Est Républicain) present in 22 departments, from the Belgian border to Avignon. 800,000 copies are distributed every day, 16.5 million unique visitors per month. The group has 4 print printing centers and digital centers hosted by the service provider of the shareholder of the EBRA group, Crédit Mutuel.

‍

Rémy Ramstein is the industrial, purchasing and CSR director of the EBRA press group. In this interview, he looks back on all the steps already taken by the group in its CSRD project, in particular the analysis of double materiality and the ongoing collection of data that will be published.

‍

Crédit Mutuel is the shareholder of the EBRA group. In this context, are you going to publish your own sustainability report or will your information be integrated into your parent company's consolidated report?

‍

Both! The EBRA group's data was already consolidated in Crédit Mutuel's extra-financial performance statement (DPEF), so there was no need to go back and no longer appear in their sustainability report. Several pages of the Crédit Mutuel report will therefore be devoted to the specific information that we are going to provide, with the 5 material impacts, risks and opportunities (IRO) specific to our business that the shareholder has chosen to retain. And for our part, we are going to publish a comprehensive sustainability report with the rest of the hardware IROs and our roadmap.

‍

Should Crédit Mutuel publish its first report in 2025?

‍

Yes before the end of March 2025 in the fiscal year 2024. So we have the same timetable to respect on our side.

‍

We completed our double materiality analysis last June and the objective now is to provide our shareholder with the expected information. It's already been done for narrative data and we've just started for quantitative data. We are currently preparing all the historical data that is already available. And we will wait until January 20 for the financial statements to be made to integrate the updated 2024 data in order to formalize the consolidated quantitative data in the Crédit Mutuel report and in the part that we are going to publish.

‍

How is the management of this project managed at EBRA?

‍

The management of CSR activities is the responsibility of COMEX, which delegated to me the coordination of the project. For our group, today we have 1/3 of my position devoted to CSR as well as a CSR project manager, associated with a financial consolidation manager who works occasionally on these subjects.

‍

We have been working on this sustainability report for a year now, since the first concrete discussions date back to autumn 2023. We obtained the necessary budget in early 2024, which allowed us to launch the double materiality analysis with a firm.

‍

In addition, our CSRD team reports to COMEX every 3 months on the progress of the project. It started with the launch and understanding of the project and then the validation of individual interviews and questionnaires for stakeholder consultation. Then there were the final decisions on the results of these interviews and the rating of the IRO. Finally, we returned the double materiality matrix last June. At the next COMEX, we will present the narrative part we have written and a first proposal for quantitative data.

‍

For your part, did you have to use pedagogy to involve everyone in the group?

‍

Yes it is a very important point. And what shows that the project is successful on our side is that the members of our COMEX can discuss CSRD today with our shareholder. But it didn't happen overnight. In the very first presentation that I gave in front of COMEX, I started by explaining what double materiality, IRO, ESRS, etc... It was a new culture that was coming, complex so there was a period of learning, of familiarization.

‍

Last May, our CFO told us that she finally understood the CSRD and in June, the CEO congratulated us for having succeeded in making the double materiality legible. So we won 2 battles, now we have to win the 3rd: the publication of the report.

‍

As you mentioned, as part of your double materiality analysis, you decided to consult your stakeholders. In what way?

‍

A total of 400 were consulted.

‍

First, we conducted individual interviews with all COMEX members and internal and external experts: journalists, employees of advertising and subscription services, heads of journalism schools, digital experts, digital experts, industry experts and suppliers. The objective was to have a very broad panel with people who express themselves about our product and our activities.

‍

Then, based on these individual interviews, we built a questionnaire distributed to 350 other stakeholders: 150 employees, 50 advertisers, 70 readers but also non-readers. What we did previously with the DPEF ended up in the CSRD project, but it is much richer, in particular thanks to the information provided by our stakeholders.

‍

Did you think it was impossible to carry out an ambitious double materiality analysis without consulting your stakeholders?

‍

The fear that we, members of COMEX, had was that we would unintentionally focus on the issues we wanted to work on and not necessarily those that our employees, our readers or our suppliers wanted us to work on. So we had to carry out the process by integrating a lot of stakeholders. I talked about it with colleagues and they too are going to do it in the same way because they think that if the approach is to be coherent and recognized, it is necessary to effectively consult the stakeholders.

‍

Before going into the details of your double materiality analysis, what are the main results?

‍

We identified 58 IROs at the start of the analysis on which we tested materiality. Of the 58, 38 stand out as materials and 5, as I was telling you, were selected by Crédit Mutuel to appear in their sustainability report. Why only 5 and why these 5? They have retained the material IROs that are specific to our industrial and journalistic activity and that are not found elsewhere in their group.

‍

{{newsletter-blog-3}}

‍

How did you rate the IRO? Did you rely on the results of the consultations with your stakeholders?

‍

In individual interviews with external and internal experts, we checked whether the IROs we identified stood out and if so, how many times they were cited, or how many times people approached the subject.

‍

We integrated these results into the questionnaires sent to the 350 other stakeholders and they were the ones who judged the relevance of the issues. And we didn't have much surprise between what we imagined internally at the beginning of the process and the responses we got from stakeholders.

‍

How did you organize your rating scale?

‍

It was a scale of 1 to 4, with a materiality threshold that we set to 2.

‍

However, two remarks related to the rating and the materiality threshold. First, there are topics in our group that we have been dealing with for years. This is the case, for example, with the prevention of corruption. This is a key point in a banking group like Crédit Mutuel. So we all take anti-corruption training every year in the company. We are so closely monitored and trained on this subject that we decided to push it under the materiality threshold. This is not because it is not important but it is so that it does not “drown out” more specific topics on which we need to make progress.

‍

Then, for all the IROs that fell under the social component, if the score of the COMEX experts was at the limit of the materiality threshold and the employee score was different, we each time preferred the employee score.

‍

So 38 hardware IROs, that means how many datapoints to collect for EBRA?

‍

On our double materiality matrix, we have grouped IROs into sustainability issues for greater readability and clarity. For example, the challenges of waste management and incoming resources of the ESRS E5 (devoted to the use of resources and the circular economy) stand out as material for us. On this ESRS alone, I have about a hundred datapoints to report back: the quantities of wastewater, the consumption of ink, the number of used machines, the tons of recycled material...

‍

‍

Another issue that is material for us is the quality of information, in ESRS S4. In fact, this is one of the issues that Crédit Mutuel decided to include in its consolidated report. We identified a negative material impact that is linked to the risk of misinformation with the rise of digital technology, the presence of white areas with non-existent or limited access to the Internet or difficulties in delivering the newspaper, for example. On this issue, we have a dozen datapoints to report to our shareholder. And what is interesting in fact is that we have “reinvented” most of these datapoints on this subject because those required by EFRAG do not correspond to our activity. We therefore decided to publish, for example, the number of journalists in the group trained to write on sustainability topics, the number of hours of training or the number of our journalists seconded to journalism schools.

‍

Another issue selected by Crédit Mutuel is the management of relationships with suppliers, including payment methods, in ESRS G1. This concerns, for example, sustainable relationships with our suppliers and management based on carbon criteria. This is a subject on which we already have a lot of data.

‍

In total, when I look at my table, we are about 400 datapoints to publish, compared to 300 previously for the DPEF.

‍

What advice would you give to businesses starting up?

‍

The first challenge is to anticipate. 1 year, for example, is far from being too long to structure the approach, launch the first steps such as double materiality analysis and then organize your collection process.

‍

Then, I advise companies to be supported and to have a good tool, shared with the various teams, to manage the project.

‍

Finally, we tell ourselves at the beginning that CSRD is a project and that in a project, there is a beginning and an end. Except in this case, there is no end. We are in a process of continuous improvement, we must accept to say to ourselves that we will improve over the coming years. And what is very interesting is that this CSRD project allows us to enrich our CSR roadmap, in particular with a committee of stakeholders that we did not have until then and that we created especially for CSRD.

‍

Why is it important to be accompanied?

‍

At EBRA, we have 1.3 FTEs devoted to CSR, i.e. not only to the CSRD project. We continue to work on the Ecovadis rating, on our carbon balances, on CSR management within the company. If you do not want to do only CSRD, you are obliged to be accompanied.

‍