Promote your responsible employer policy as part of the CSRD

Background

A major French bank, the leading financier of the French economy and the leading local bank in Europe, must comply with the new European directive on sustainability reporting (CSRD) by promoting its ‘human project’ and its HR excellence approach to its stakeholders (rating agencies, employees, applicants, etc.). To achieve this, the Group HR Department must draw and walk a crest line that is compatible with regulatory transparency requirements (ESRS 1, 2 and S1 nomenclature) and reputational issues (impacts, risks and opportunities of its policy).

Challenge

The European directive confronts the Group HRD with the relevance and coherence of its CSR policy with regard to the challenges and criteria imposed on all large companies (working conditions, diversity, inclusion, parity, equity, etc.). From a technical point of view, it must produce and report on all the quantitative indicators that relate to material issues for the Group. From a strategic point of view, it must show its stakeholders that its HR policy enables it to meet these challenges by defining ambitious objectives and implementing proportionate policies and action plans. To do this, it must mobilise and lead the HR function in all the Group's subsidiaries and entities, while adhering to the governance, workstreams and planning defined for the CSRD project.

Approach

Keyrus Management supported the HR Department in the production of indicators (quantitative data points), and in the formalisation of HR policies by analysing the discrepancies between existing content (DPEF, HR communication media) and publication requirements on the one hand, and by framing the communication strategy (between transparency, consistency and commitment) on the other. Keyrus Management coordinated workshops to collect, evaluate and consolidate Impacts, Risks and Opportunities (IROs) as part of the dual materiality approach. This support consisted in being able to objectify and justify the ratings made with the stakeholders. Keyrus Management also collected and analysed the qualitative content describing the Group's HR policy, in order to assess its relevance in relation to the normative requirements and to formalise the narrative elements of the report. Finally, Keyrus Management defined the RACI and the procedure for producing the report as part of the project management and the continuous improvement approach implemented for 2025.

Key results

Benefits

By clarifying all the regulatory and political issues surrounding CSRD, the assignment enabled the Group HR Department to regain control of the HR aspect of the project, to assert its role as orchestrator and facilitator vis-à-vis the HR function and to turn a regulatory requirement into a strategic lever for enhancing the Group's employer brand.

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