A group with multiple entities rarely has a single answer to the question of who is responsible for what. The parent company reports, but the data originates at subsidiaries, joint ventures or foreign locations. As soon as a board must demonstrate that an obligation has been met, the question arises of what exactly counts as evidence for that, and where that evidence currently resides.
An annual report or sustainability report shows an outcome, not a process. For a board that wants to be in control, what counts is not only the end result, but also the trail leading to it: who supplied the data, on the basis of which source, with what approval, and at what point in time. For a single entity, that trail can usually be found within one department. For a group, the trail runs through multiple systems, languages and responsibilities, which makes the question of what counts as evidence less straightforward than it sounds.
Data on energy consumption, personnel, suppliers or risks typically originates locally, at the entity where it actually happens. From there, it is consolidated to group level. In that movement from local to central, evidence easily becomes detached from its origin: a figure lands in a spreadsheet without it still being traceable which location supplied it or which assumption is built into it. Anyone who wants to know precisely where evidence gets scattered in a group with multiple entities will see that this usually happens at the transitions between systems, not within a system itself.
A group-wide policy document describes a standard, not an action. An auditor or supervisor asking whether an obligation has been met is in fact asking whether the policy has also been applied, and whether that is demonstrable per entity. A centrally established policy document says little about whether a subsidiary in another country has actually implemented that policy. How that step from standard to practice is made demonstrable is described on the page about how you demonstrate that policy is also practice in a group with multiple entities.
Evidence that no one regards as their task is not maintained, and therefore not found at the moment it is needed. In a group with multiple entities, the question of who owns an obligation is therefore just as important as the question of what needs to be proven. Without a designated owner per obligation, there is a risk that evidence is collected in multiple places at once, or nowhere at all. The page about who owns an obligation in a group with multiple entities describes how that assignment relates to the structure of the group.
A document stored somewhere is not automatically a document an auditor will actually encounter. With multiple entities, each with its own systems and its own archiving habits, the distance between retaining and finding is often greater than is assumed at group level. That topic, how evidence is retained so that it is findable at the right moment, is worked out on the page about how you retain evidence so that an auditor finds it in a group with multiple entities.
An additional layer of complexity: the same European obligation can be implemented differently per country. What counts as sufficient evidence in one country does not suffice in another, because the national legislator has added its own requirements to the European base. For a group with locations in multiple countries, this means that a single evidence standard does not automatically suffice everywhere. An example of what such a national add-on looks like is described on the page about which national add-ons apply in Germany.
It is tempting to see evidence as something you collect: the more documents, the stronger the position. For a board that must demonstrate it is in control, structure is more important than volume. For each obligation, what is relevant is who the owner is, which evidence belongs to it, and which control demonstrates that this evidence is also current and reliable. Without that link between obligation, owner, evidence and control, a collection of documents remains just that: a collection, not demonstrability. How that link is recorded is described on the page about what a control matrix is in a group with multiple entities.
Mapping out who manages which evidence, where that evidence originates and how it remains findable is work that largely consists of ordering existing information. Part of that ordering work, such as tracing data back to its source or flagging missing links, lends itself to support by AI. FTE TO AI offers a work scan that calculates, per task, which part of the work can be taken over by AI; anyone who wants to know how much of the evidence and demonstrability work within a group lends itself to this will find a starting point there.
Vraag maar welke verplichting op u van toepassing is, en waaraan u dat kunt aantonen.
Answers come from this site’s knowledge base. Not tailored advice, and not a scan of your company.