VSME Comprehensive Module Data Checklist

Document your company legal form, NACE code(s), entity identifier (LEI, DUNS, EUID or equivalent), reporting basis (individual or consolidated), countries of operation, and the sites you own, lease or manage. If you report on a consolidated basis, also gather a list of subsidiaries with their registered addresses.

Document the significant groups of products and services you offer, the significant markets you serve (B2B, wholesale, retail, countries), the main business relationships covering customers, distribution channels and partnerships, and the elements of your strategy that relate to sustainability. Supplier specifics live in the separate supplier-profile item.

Three procurement data points covering your supplier base during the reporting year: an estimate of the total number of suppliers you worked with, the main sectors those suppliers operate in (food processing, packaging, logistics, and so on), and the main countries they are based in. Plain-English lists are fine; aim for the picture of where your spending concentrates, not a line-by-line inventory.

Balance sheet total, turnover, number of employees (headcount or FTE), and any sustainability certifications. Use the same reporting period as your financial statements.

Document the practices, written policies, and any future initiatives you have for each environmental topic below. Include any targets you have set (e.g. emissions cuts, packaging reduction). A short paragraph per topic is enough. "None in place" is a valid answer.

• • Climate change — Energy efficiency, switching to renewable electricity, fleet electrification, building retrofits, or any GHG-reduction commitment.
• • Pollution prevention and control — Air, water, or soil pollutants from your operations: filters, spill controls, low-VOC materials, or substitutions for hazardous substances.
• • Water and marine resources — Water-saving measures, recycling, leak detection, or discharge-quality controls. Most relevant if you have water-using production.
• • Biodiversity and ecosystems — Site-level habitat protection, no-pesticide grounds, certified supplier sourcing (FSC, MSC), or biodiversity offsets.
• • Circular economy — Reuse, repair, recycled-content inputs, take-back schemes, packaging redesign, or waste-diversion targets.

Document the practices, written policies, and any future initiatives you have for each social topic below. Include any targets. A short paragraph per topic is enough. "None in place" is a valid answer.

• • Own workforce: working conditions and rights — Working hours, wages above the legal minimum, health and safety beyond the legal floor, training, diversity, parental leave, freedom of association.
• • Workers in the value chain — How you check labour conditions at suppliers and subcontractors: supplier code of conduct, audits, modern-slavery checks.
• • Affected communities — Engagement with local residents around your sites (noise, traffic, dust), community investment, indigenous-rights commitments where relevant.
• • Consumers and end-users — Product safety, accurate marketing, data protection, accessibility, protections for vulnerable customers.

Document your practices, policies, and future initiatives on business conduct, plus any sustainability certifications held during the reporting year.

• • Business conduct and ethics — Anti-bribery and anti-corruption rules, whistleblowing channel, conflict-of-interest policy, gifts-and-hospitality limits, supplier ethics standards.
• • Sustainability certifications and labels — Third-party certifications held during the year: ISO 14001, ISO 45001, B Corp, EU Ecolabel, EMAS, Fairtrade, FSC. Note the scope and certifying body.

Name and role of the most senior person responsible for putting your sustainability practices, policies and future initiatives into effect. For most small and growing businesses (SMEs) this is the managing director, a board member, or the head of operations. One named person, not a team or committee.

Headcount by contract type (permanent and temporary), by gender, and by country if you operate in more than one. Once total headcount (permanent plus temporary) reaches 50, also collect the year's employee turnover and the average headcount across the reporting year.

Number of recordable work-related accidents, total hours worked, fatalities from work-related injury, and fatalities from work-related ill health. Document your safety programmes alongside the numbers. For total hours, use the country-norm hours per worker (around 1,645 in France, 1,750 in Germany, 1,800 in Italy) rather than a flat figure.

Average training hours per year for male and female employees (recorded separately), the percentage of employees covered by collective bargaining agreements, minimum-wage compliance, and the gender pay gap.

Headcounts by gender for managers as a count pair (female and male). The female-to-male ratio is derived from the pair, not stored as a percentage. "Management" usually means the level immediately below the board, or the equivalent senior leadership tier; if you use your own definition, note it. Also count self-employed contractors working exclusively for you (a contractor with any other significant commercial client during the reporting period does not qualify) and the number of temporary workers provided by employment agencies.

Record whether you have a code of conduct or human rights policy for your own workforce, and whether you have a complaints-handling mechanism. If a policy exists, log which of the five named areas it covers. Tick "Other" only for topics outside this list.

• • Child labour — Minimum-age rules at your operations and at the suppliers you control.
• • Forced labour — Prohibitions on bonded labour, retained passports, debt bondage; modern-slavery checks.
• • Human trafficking — Recruitment-fee bans, source-country due diligence, victim-support commitments.
• • Discrimination — Equal treatment on gender, race, age, disability, religion, sexual orientation.
• • Accident prevention — Workplace safety rules, near-miss reporting, PPE provision.

Two scopes to track separately. Own-workforce incidents use the four named categories (child labour, forced labour, human trafficking, discrimination) or "other". Incidents involving workers in the value chain, affected communities, and consumers and end-users are recorded as a short narrative rather than fitted to the named categories. Document the remediation actions taken in both cases. If none in either scope, record "zero" for transparency.

If you have a formal governance body (board of directors, supervisory board or equivalent), record headcounts by gender for its members as a count pair (female and male). The female-to-male ratio is derived from the pair, not stored as a percentage.

Monthly energy use covering electricity (kWh), natural gas (m³ or kWh), heating oil (litres), and any other fuels (diesel, petrol, propane, biomass). Track the renewable and non-renewable split for electricity.

Calculate Scope 1 emissions from fuel consumption and Scope 2 emissions (location-based) from electricity consumption, plus GHG intensity (total emissions ÷ turnover). Use GHG Protocol methodology.

Set GHG emission reduction targets for Scope 1 and Scope 2 (target year, base year, values, units). Set Scope 3 targets if you disclose Scope 3. For each scope, record the share of the scope your target covers (typically 100%). Capture the main actions you plan to take (switching to renewable electricity, fleet electrification, warehouse insulation, and similar). Develop a transition plan if you operate in a high climate-impact sector.

Identify the climate-related hazards and transition events that create risks for you. Assess how exposed and sensitive your assets, activities and value chain are to those risks. Document the time horizons considered, the adaptation actions taken, and the potential adverse effects on financial performance over short, medium, and long term.

Track pollutant releases to air, water and soil by substance and quantity. Document the public disclosure URL if your pollutants are already publicly disclosed under another regime (E-PRTR, national equivalents).

Identify sites located in or near biodiversity-sensitive areas (Natura 2000, Key Biodiversity Areas, nationally protected areas). Record site areas in hectares and, optionally, land-use metrics such as sealed area and nature-oriented area.

Total water withdrawal per site, and a flag for whether the site sits in a water-stress area. For each site, decide whether it has production processes that significantly consume water (thermal energy, manufacturing, agricultural irrigation). Water discharge and the resulting consumption figure (withdrawal minus discharge) are only required for those sites; offices and warehouses without water-consuming processes can skip the discharge measurement.

Classify waste as hazardous or non-hazardous and track quantities by type (mixed municipal, paper and cardboard, plastics, metals, food waste, and so on).

Quantify the total waste diverted to recycling or reuse, and document which circular-economy principles you apply (reuse, repair, remanufacture, recycling, and similar).

Annual mass-flow of the significant materials you use (steel, aluminium, plastics, paper, food, and so on).

Number of convictions for corruption or bribery violations during the reporting year, and the total amount of fines for those violations. If none, record "zero" for transparency.

Record any revenue from restricted sectors and whether you fall under any of the four EU Paris-aligned benchmark exclusion thresholds. The restricted sectors are controversial weapons (anti-personnel mines, cluster munitions, chemical or biological weapons; sporting firearms and other NACE 25.40 weapons do not qualify), tobacco cultivation and production, fossil fuels (coal, oil, and gas, disaggregated), and pesticide and agrochemical production.

Decide whether your report will leave anything out under EU classified-information rules (Council Decision 2013/488/EU) or sensitive-information rules (Regulation (EU) 2021/697). If yes, a short note describing which disclosure was omitted is enough. The standard asks you to indicate that something was withheld, not to disclose the content itself.