2023 Transparency Criteria

The full list of the 289 Transparency Criteria

UPDATED: 28 JUNE 2023

THE UNIVERSAL REGISTRATION DOCUMENT

  • Existence of an introduction to the document, selecting the company's relevant and forward-looking information
  • General summary on the inside front cover with chapters and sub-sections (2 levels)
  • Indication in the summary of the items comprising the Annual Financial Report
  • Intermediate summaries at the start of each chapter, with 3rd level headings
  • Presence in the general summary of a CSR or "Non-financial Performance" chapter
  • Existence of an Integrated Report (IR)
  • Presence in the general summary, or intermediate summary, of a section summarizing the company's communication and dialog with shareholders/investors/managers
  • Presence in the overview of a "Strategy and objectives" section
  • Presence of a "Taxonomy" section clearly identified in the summary of the CSR/NFPS chapter
  • Document in a single volume
  • Name "Universal Registration Document" 
  • Existence of an English version
  • Name "Universal Registration Document"
    Indication of chapters and sub-sections on the top of the page on the outside edge
  • Indication of the company, title of the document and year at the bottom of the page
  • Two-column presentation
  • Index by key words
  • Existence of a glossary (30 terms and more)
  • Easily accessible information on the parity, independence and nationality of directors on the Board, at least in the form of key figures
  • Equity ratios presented in graphic or table form in the report on ex-post compensation
  • Summary preceding the notes to the financial statements
  • Presence of graphs in the notes to the consolidated financial statements (3 minimum)
  • Cross-reference table with Regulation (EU) 2017/1129 including chapters and sub-sections
  • Cross-reference tables for the Annual Financial Report
  • Cross-reference tables for the Management Report
  • NFPS cross-reference tables
  • Number of pages and/or sections in all the cross-reference tables
  • Cross-reference tables for the Corporate Governance Report
  • Duty of Care cross-reference tables
  • TCFD cross-reference tables
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  • Annual Financial Report included and cited on the cover
  • Annual Report for the General Meeting included
  • The list of regulated information published during the last 12 months or a precise reference to the website
  • Selected financial information presented for at least three years
  • Similar sector segmentation
  • Mention of revenue and results of various operating segments and by geographic area in the description of activities
  • Mention of ESG topics in the strategy and of a forward-looking item giving a time line
  • Short introduction to the "Risks" chapter or to the "Risk Factors" section summarizing the main risks
  • Presentation of each risk in two clearly identified parts: risk identification and risk management
  • Precise references from the "Risks " chapter
  • Existence of a risk mapping or a table summarizing the main risks
  • Risks: presentation of about 10 risk categories and sub-categories and a maximum of 15 risk factors
  • Risks: presence of an item enabling the assessment of the net criticality of the risks (value scale, mention, pictogram, amount, etc.)
  • Risks: identification of ESG risks in the summary presentation of the main Group risks
  • NFPS: Presentation of the reporting methodology and its scope
  • Existence of a materiality matrix presenting the dual materiality and the methodology used
  • NFPS: Presence of the verification certificate by an independent third party
  • NFPS: Identification of the indicators covered by the assurance given by the independent third party
  • Presentation of the main items making up the non-financial rating or reference to the corporate website or the website of the non-financial rating agency or presentation of a history of the rating (over at least two years)
  • Presentation of a selection of important non-financial risks in table form
  • Human rights: Identification of human rights risks related to the company's activities by geographical area and presentation of related action plans
  • Environment: identification of the most critical environmental risks by geographic area and related action plans
  • Presentation of the CSR, Compliance and Cybersecurity organization stating a clear reporting line to the Executive Committee/Management Committee
  • Presentation for each non-financial risk of its criticality level and/or change in impact (textual or visual information)
  • Inclusion of the alignment of climate policy with the 2 degree trajectory (or 1.5 degrees) with details of the methodology for choosing the objectives and the means and resources used to achieve the objectives
  • Presence of indicator(s) on biodiversity and related objective(s)
  • Reference to a mapping of sites, assets and/or activities presenting a biodiversity risk
  • Publication of carbon reduction or neutrality objectives expressed in absolute terms and for the 3 scopes
  • Breakdown of scope 3 according to the 15 categories of the GHG Protocol
  • Specification of the share of reduction and the share of offset in the carbon neutrality approach (in graphic form or as a %)
  • Mention of following the Science Based Target Initiative (SBTi)
  • Specification of the "Gross Risk" impact for CSR risks
  • Specification of a degree of confidence (or uncertainty) in the climate indicators/objectives
  • Presence of a section dedicated to sharing value with employees detailing the results of the various mechanisms in place
  • Revenues eligible for the SDGs selected by the company
  • Publication of the 14 mandatory Principal Adverse Impacts (PAIs) in the form of a cross-reference table
  • Presence of the methodology for analyzing the eligibility/alignment, or not, with the taxonomy
  • Indication of the base year used to define the carbon emission reduction objectives
  • Scope 3: details of the scope, methodological principles, assumptions used and level of uncertainty
  • Reference to a Marketplace Governance Code
  • Annual review of the independence of the Board members
  • Identification of the members of the Audit Committee and details about their skills
  • Statement of overall and individual attendance at Board meetings, as well as the number of meetings
  • Statement of overall and individual attendance at committee meetings, as well as the number of meetings
  • Reference to the implementation of a succession plan, the date of its last review and details of the work carried out during the review
  • Opinion on the assessment of the Board with recommendations
  • Presence of the company's own definition of "business relationships"
  • Presence of the Internal Rules of the Board of Directors or of the Supervisory Board
  • Existence of Board of Directors' training
  • Existence of a CSR Committee or presence of CSR in the work of the Board
  • Existence of an Ethics Committee or presence of ethics in the work of the Board
  • Details of Board meetings held without the presence of the executives and the topics discussed in a clearly identified section
  • Existence of a Compensation Committee separate from the Appointments Committee
  • Mention of the existence of a management process for inside information
  • Presence of the policy for monitoring and approving regulated agreements drawn up by the Board of Directors
  • Specification of the type of participation (physical, videoconference) in Board meetings for each director
  • Presentation of the process for selecting directors
  • Presence of the diversity policy in the management bodies (Executive Committee/Management Committee) with precise diversity objectives, the action plans implemented and the time line
  • Description of CSR skills/expertise on the Board
  • Presence of environmental issues in the work of the Board
  • Existence of an annual stakeholder consultation process within the Board/a specific Board and/or Executive Management committee
  • Breakdown of men and women in the management bodies (Management Committee/Executive Committee) and among executives and publication of the proportion in the form of key figures
  • Existence of CSR/climate issues training for directors and the number of directors trained
  • Presence of an employee director on the Compensation Committee
  • List of discussions, excluding the presence of the executives, with the employee director(s)
  • Reference in the work of the Audit Committee of its contribution to the preparation and control of non-financial information (climate, biodiversity, social and governance)
  • Presence of the equality index (gender pay gap) accompanied by the actions implemented and the time line, if the index is less than 75 points, or the objectives for progress on each indicator if the index is less than or equal to 85 points, or a precise reference to the website
  • Presence of the calculation methodology for the equality index including all compensation paid (fixed + benefits)
  • Mention of the participation of the CSR Committee/CSR representative of the Board in the development of variable compensation criteria and the performance assessment of executives with respect to these criteria
  • Specification of the respective roles of the Audit Committee and the CSR Committee with regard to non-financial performance reporting (NFPS)
  • Report of the Statutory Auditors on regulated agreements
  • Variable compensation of executives as a percentage of fixed compensation
  • Methods for fixing the amount of variable compensation and presence of qualitative and quantitative criteria and their weighting in table form
  • Conditions for holding shares resulting from the conversion of stock options or the granting of free shares or performance shares
  • Presence of a graph comparing the change in compensation with the change in the company's financial and non-financial performance
  • Presence in the compensation policy report of all the components of compensation subject to a vote
  • Specification of the compensation per director, including the distribution rules
  • Presence in the compensation policy of a table summarizing the amount of indemnities and benefits potentially due to executive corporate officers under different departure assumptions
  • Specification of the criteria used to determine compensation in the compensation policy
  • Presence of a table summarizing the regulated agreements in effect and to be voted on, specifying the interest for the company, the level of significance and the services effectively invoiced
  • Presence of the methodology used to calculate the equity ratios, with details of the percentage of the workforce represented in the scope of consolidation, all components of the compensation of executive corporate officers and all compensation paid or allocated to employees during the year, or justification for not including them
  • Publication of a ratio representing 80% or more of employees and/or an additional ratio for France and/or Europe
  • Presentation in a table in accordance with the AMF model of the achievement rates of the objectives set by criterion for the determination of annual variable compensation
  • Presence of a summary table of the results of the votes on all resolutions relating to corporate officer compensation at the previous GM
  • Reference to a code or charter of ethics with specific references
    Presentation of the Duty of Care Plan incorporating the five mandatory pieces of information
  • Reference to the implementation of a personal data protection program
  • Mention and description of an anti-corruption plan in a clearly identified section
  • Reference to Human Rights governance
  • Duty of care: publication of a risk mapping or mention of the most critical risks and the procedures implemented to manage them
  • Presentation of the compliance system in place
  • Presentation of the results of the ethics whistleblowing system in place, including at least the number of alerts received and processed and the sanctions imposed
  • Mention of an ethics training program and the number or percentage of employees trained
  • Mention of the existence of a network of "part-time" ethics correspondents in the group
  • Mention of the existence of an ethics whistleblowing system with a description of the system or specific reference to a specific document, the ethics charter or the website
  • Specification in the description of the whistleblowing procedure of an acknowledgement period of less than or equal to seven days
  • Specification of the last date of update of the code of ethics/code of conduct and of the corruption risk mapping
  • Mention in the ethics system of the implementation of knowledge tests following employee training sessions and the number of tests carried out during the year
  • Inclusion of self-financing capacity in the cash flow statements
  • Environmental risks: mention the impact of climate commitments on financial performance
  • Presentation of the work done to assess the impact, or otherwise, of climate commitments on the company's financial performance (main judgments, estimates made and time line used)
  • Voting rights of shareholders holding more than 5% of the share capital
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  • Summary in 6 to 10 chapters
  • Didactic structure of the document
  • Relevant chapters named "Risk Factors and Management", "Corporate Governance" and "Non-Financial Performance Statement"
  • English version identical to the French version, page for page
  • Presence of key financial performance indicators (at least 1 indicator from the balance sheet, income statement and cash flow statement) and non-financial indicators (at least 2 indicators representative of the 3 ESG pillars) in the presentation of activities or in the introduction to the document
  • Presentation in graphic form of risk governance
  • NFPS: reference to a national or international standard
  • NFPS: existence of a table/mapping of stakeholder dialog
  • Presentation in the form of a dashboard of CSR issues, objectives over time, assessment criteria and key performance indicators, deadlines set and progress made
  • Presence of the business model presented graphically and integrating, at least, quantified value creation (presence of KPIs) and market trends
  • NFPS: presentation of each non-financial issue in 3 parts, implicit or explicit: 1. Risk 2. Policies 3. Performance indicators
  • Presentation of the SDGs in relation to the company's CSR approach and the associated action plans
  • Presentation of greenhouse gas emissions in TeqCO2 (metric tons equivalent of CO2)
  • Presence of a graph describing the low-carbon trajectory over time compared to the objectives to be achieved (set by the company/Paris Agreement) with details about the model or methodology used
  • Presentation of non-financial indicators over a minimum of 3 years
  • Use of one or more biodiversity strategy standards (EU Biodiversity Strategy for 2030, Rio Declaration, Post 2020 Global Biodiversity, Act4Nature, SBTN, etc.)
  • Presence of three Green Taxonomy business tables (Revenue, Capex and Opex) and presence of at least one extract from one of these tables with comments
  • Comparison of the company's carbon trajectory, from the selected base year, to the projection of a scientific/reference trajectory (sectoral, IPCC, SBTi, etc.)
  • Summary table presenting the Board's composition
  • Governance: presence of a table summarizing the AFEP-MEDEF or Middlenext recommendations not applied
  • Compensation: presence and compliance of the 11 tables of the AMF recommendation
  • Compensation: presence of the 11 tables of the AMF recommendation numbered accordingly
  • Presence of a quantitative "environmental" criterion and "social" criterion, in line with the ESG strategy, in the calculation of short-term and medium- to long-term variable compensation and specification of their respective proportions
  • Presentation in table or graph form of a summary of all compensation paid (short-term and medium- to long-term) during the fiscal year, including deferred compensation from previous years
  • Graph or table-based changes in equity ratios over the last five years in relation to annual changes in compensation, company performance and average employee compensation
  • Presence of non-financial criteria in the variable compensation of Management Committee/Executive Committee members
  • Interest rate and currency risk sensitivity tables
  • Structured summary of the notes to the consolidated financial statements
  • Structure of the notes to the consolidated financial statements
  • "Reference year" column on the left in the financial statements
  • Capital structure, with important subtotals, relevant lines and distinction between theoretical and exercisable voting rights in a table showing changes over 3 years
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  • Filing date with the AMF maximum 5 days after the average filing date of the index
  • Publication of the English version no later than 7 days after the date of filing of the French version with the AMF
  • Maximum difference between the date of publication of the results (press release) and the filing with the AMF = average difference of the index + 2 days

THE WEBSITE

  • "Regulated information" section from the "Group" or "Investors" home page
  • Not more than two clicks to access the URD/Annual Financial Report from the "Investors" home page
  • Existence of a menu with direct access to the sub-sections
  • Search engine performance
  • Existence of a "site map" with menu and sub-menus
  • Direct access to the Universal Registration Document for the current year via a browser
  • Existence of an interactive version of the Universal Registration Document
  • Interactive version of the Universal Registration Document: presence in the "Regulated information" section, as well as the PDF
  • Option to subscribe to an RSS feed or an email newsletter
  • Prior consent for the use of cookies: presence of three options, i.e., "Refuse all", "Accept all" and "Personalize my choices"
  • Presence of the multi-year plan to make the site accessible, together with annual action plans, for a maximum of 3 years
  • The URD is available in PDF format in addition to the ESEF version
  • Publication of the URD in xHTML format with reader in the Investors section of the corporate site
  • Adaptation of the URD's ESEF format to on-screen reading: presence of an interactive menu and one-column layout
  • Digital version of the Half-Yearly Financial Report available on the corporate website
  • Sustainable Development or CSR tab clearly identified and accessible on the site
  • CSR report/CSR chapter of the URD accessible from the CSR tab
  • Existence of a correspondent point of contact in the CSR tab
  • Easy access (in three clicks) to the gender equality index, the results obtained for all the indicators of the index, the corrective measures to be taken if the index is less than 75 points and the targets for progress for each of the indicators if the result is less than or equal to 85 points
  • Information on regulated agreements easily accessible (three clicks maximum)
  • Presence of a section/sub-section dedicated to ethics grouping together at a minimum the ethics charter and related themed charters and including a glossary
  • No more than two clicks to access the Notice of meeting brochure and/or the notice of meeting in the BALO (French journal of mandatory legal announcements)
  • Presence of the necessary documents for the General Meeting in the section "Information for the General Meeting" of the "Regulated information" section
  • Existence of a complete and updated "General Meeting" tab
  • Interactive version of the Notice of meeting brochure
  • Information on votes rejected in the GM
  • Presence on the GM home page, in a specific document/section, of an explanation on how the GM is held and the ways to participate
  • Easy and public access to the presentation slides of the annual results
  • Ability to send an email to investor relations
  • Presence of the investors' presentation slides (roadshows and other meetings)
  • Presence of ESG roadshow/ESG Capital Day presentation slides
  • Digital version of the URD: Dynamic summary
  • Digital version with an Excel download center enabling the download of all of the Excel tables in the document in one click
  • Option to bookmark the content to create a working document online
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  • Effective presence of all regulated information items as defined in Article 221-1 of the AMF's General Regulation in the dedicated section
  • Presence of press releases regarding availability and of periodic documents in the "Regulated information" section
  • Presence of the last five Annual Financial Reports (or URDs) in the "Regulated information" section
  • Indication of the publication date of the documents
  • Indication of the size of the documents
  • Presence and quick access to the company's updated bylaws in the GM section or direct link to the updated document
  • Consistency between the name on the site and the cover of the annual and half-yearly documents
  • Presence of the declaration of accessibility and/or the percentage of accessibility
  • Presence of the summary presentation of the CSR strategy and the main non-financial indicators in investor presentations
  • Presence of non-financial indicators/topics in the press release of annual results
  • Presence of the date of next year's General Meeting in the timetable
  • Presence of minutes of the GM (transcript, webcast, minutes)
  • Presence of the slides shown at the GM
  • Clarification of the title of the resolution in addition to its number in the table showing the results of the votes and the details of the quorum
  • Timetable of the main meetings beyond 6 months from now
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  • Easy access through the company's website search engine to the "ethics", "corruption", "strategy" and "sustainable development" topics
  • Name of the section: "Investors" (with, if necessary, another associated term)
  • "Investors" home page identical in the French and English versions
  • Title "Regulated information"
  • Title "Regulated information"
  • Distinction made between "Periodic information" and "Permanent information"
  • At least the "Activities", "Strategy", "Governance" and "CSR" sections appear on the home page of the corporate site, alongside the "Investors" section
  • No blocking errors in the ESEF file
  • Minimum presence of the "News", "Agenda", "Contacts" and "Stock market prices" sub-sections in the "Investors" section
  • Online presence of a document in "machine-readable" format from native Html
  • Presence in the GM section of a sub-section dedicated to written and verbal questions as well as answers given before or at the GM

NOTICE OF MEETING BROCHURE

  • Paginated summary, on outside or inside front cover
  • Presence of navigation markers in the document
  • Publication of a Notice of meeting brochure
  • Title "Notice of General Meeting brochure"
  • Merger of the presentation/objectives and the draft resolutions
  • Existence of an English version
  • Document available in a version for the visually-impaired
  • Presence of a summary table presenting all applicable regulated agreements
  • Presence of the report on ex-post compensation
  • Presence of an executive summary summarizing the compensation policy and the elements used to assess the compensation paid
  • Option to vote electronically before the GM
  • Option to send written questions by email
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  • Presence on the cover of the date, time, place and way of holding the GM
  • Presence of a personalized message from the Chairman
  • Presence of the information required by Article R. 225-81 of the French Commercial Code
  • Presence of non-financial indicators in the summary statement or in the key figures of the year
  • Summary presentation of the company's climate (environmental) strategy with, at a minimum, the objectives pursued and the actions implemented
  • Information on the directors in office, to be appointed, or to be re-appointed
  • Graphical presentation of the Board's composition
  • Information on attendance at Board meetings
  • Presence of arguments explicitly justifying the proposal to appoint or re-appoint directors, in particular the value-added of the candidates compared to the skills already present on the Board.
  • Presence of the table on the use of current delegations of authority
  • Easy access to information on the dates of appointment and re-appointment of directors
  • Presentation of a summary of the activity of the Board of Directors Committees
  • Presentation of a summary statement on the activity and assessment of the Board
  • Presentation of the main elements of compensation in graphic form
  • Presence of the main elements of compensation, fixed and variable, over the last five fiscal years, at a minimum
  • Summary of the compensation policy
  • Presence of a resolution per executive corporate officer for the presentation of the elements of compensation submitted for ex-ante vote
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  • Structure didactique
  • Summary statement including, at a minimum, commentary on the results, summary tables of the financial statements, outlook, and/or events after the closing date
  • Effective presence of all necessary information for an informed vote in terms of governance, compensation and regulated agreements
  • Mapping of the main skills within the Board of Directors
  • No broadcasting of information relating to directors whose re-appointment or appointment is submitted to the GM
  • Presentation of regulated agreements submitted to a vote
  • Presence of the AFEP-MEDEF table on compensation
  • Presence of an explanation of the four ways to vote
  • Minimum time between the date of the notice of meeting in the BALO and the GM
  • Maximum time between the closing date of the fiscal year and the GM
  • Deadline for taking into account postal votes or via Internet up to four days before the GM
  • Deadline for consideration of written questions sent by mail or via the Internet up to 48 hours before the GM
  • General Meeting with physical presence and live-stream
  • Questions can be asked verbally during the GM by shareholders participating remotely
  • Mention of the possibility to give "proxy to a third party" by mail until four days before the GM, or by electronic means until the day before the GM, with details about the practical ways of communicating voting intentions by the proxy
  • Possibility of reconsidering a vote that has already been cast and the practicalities of doing so
  • Written and verbal questions and answers will be available on the website no later than the day after the GM
  • Provision of a replay of the General Meeting on the issuer's website after the meeting
  • Specification, in the Brochure or a press release, of the name and position of the two scrutineers appointed from among the company's shareholders
  • Presence in the GM section of the website of a standard form for requesting documents related to the GM, which can be modified
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Plain Language Criteria

  • Less than 20 words per sentence
  • Maximum 20% complex sentences
  • Not more than 80 words per paragraph
  • Not more than four paragraphs after a sub-heading/intermediate heading
  • Less than 20 words per bullet point
  • More than 98% of the sentences in active voice
  • More than 98% of sentences in the affirmative form
  • Not more than 1% of non-verb sentences
  • Not more than 15% of sentences with parentheses
  • Less than 7% of adjectives
  • Less than 2% of adverbs
  • Less than 0.5% of latinisms, anglicisms or English words
  • Less than 0.5% of jargon, technical or antiquated words
  • At least 25% of headings including a verb