For Indicator 3, and similarly for Indicators 7 and 14, the SFDR Delegated Regulation expects you to report the weighted average result, not a pure absolute count. You should express the result relative to investment exposure (for example, “per million EUR invested”) rather than just giving a raw total number of workdays lost.
In Annex I, Table 3, indicator 3 (Number of workdays lost to injuries, accidents, fatalities or illness of investee companies expressed as a weighted average) - may this be reported as absolute or relative numbers? Or does the Regulation dictate one or the other? The question is also applicable to Table 3, indicators 7 and 14.
The metrics for indicators 3, 7 and 14 of Table 3 indicate that the value of the impact should be expressed as a weighted average. Financial market participants should refer to the definition of “weighted average” in point 3 of Annex I of the Delegated Regulation. Furthermore, while the metrics for those indicators do not contain the words that the result should be expressed “per million EUR invested” (unlike indicators 8 and 9 in Table 1 and indicators 1, 2, 3 and 13 in Table 2), to achieve the relative responses desired by the ESAs, these metrics (indicators 3, 7 and 14) in Table 3 should also be expressed in relative terms, i.e. “per million EUR invested”. The annual disclosure should be based on at least four quarterly calculations based on the investments of the financial market participant, as described in Article 6(3) of the Delegated Regulation. The quarterly impacts should be based on the latest available information from investee companies or other entities.
European Supervisory Authorities (ESAs)
