ECA sustainability report 2021.
Date: 2022-12-09
Institutions: European Court of Auditors
Subjects: European Communities, European Court of Auditors, biodiversity, consumer protection, corruption, economic consequence, energy consumption, environmental impact, environmental standard, ethics, financing method, governance, health policy, human rights, labour market, local authority, occupational safety, performance measurement, prevention of delinquency, public policy, purchase, reduction of gas emissions, slavery, social impact, sustainable development, trade union freedom, waste management

2021 

ECA SUSTAINABILITY REPORT 

ECA 
SUSTAINABILITY 
REPORT 

2021 

12, rue Alcide De Gasperi – L-1615 Luxembourg 
T +352 4398-1 

  E eca-info@eca.europa.eu 

  eca.europa.eu 

 
Contents 

FOREWORD BY THE SECRETARY-GENERAL:  
THE ECA'S SUSTAINABILITY REPORT 

INTRODUCTION: REPORTING PRINCIPLES 

GENERAL DISCLOSURES 

Organisational Profile 

Strategy 

Ethics and integrity 

Governance 

Stakeholder engagement 

Reporting practice 

Management Approach 

ECONOMIC STANDARDS 

Economic Performance 

Labour market presence 

Indirect Economic Impacts 

Procurement Practices 

Anti-corruption 

ENVIRONMENTAL STANDARDS 

Energy 

Water and Effluents 

Biodiversity 

Emissions 

Waste 

Environmental Compliance 

Supplier Environmental Assessment 

2 

Page 

5 

7 

10 

11 

14 

15 

18 

21 

23 

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25 

25 

27 

30 

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33 

34 

35 

35 

36 

36 

37 

38 

 
SOCIAL STANDARDS 

Employment 

Labour/Management Relations 

Occupational Health and Safety 

Training and Education 

Diversity and Equal Opportunity 

Non-discrimination 

Freedom of association and collective bargaining 

Child labour, forced or compulsory labour, rights of indigenous 
peoples 

Security Practices 

Human Rights Assessment 

Local Communities 

Supplier Social Assessment 

Public Policy 

Customer Health and Safety 

Socioeconomic Compliance 

ANNEX 

3 

39 

40 

41 

42 

46 

48 

49 

49 

49 

50 

50 

50 

50 

51 

51 

51 

52 

 
 
 
 
2021 ECA College 

4 

From left to right, and top to bottom: Mr Opioła, Ms Elvinger, Mr Cazala, Ms Berger, Mr Ştefan, 
Mr Takkula, Ms Lindström, Ms Gáll-Pelcz, Mr Murphy, Ms Turtelboom, Ms Maletić, Mr Brincat, 
Mr Kozlovs, Mr Jereb, Ms Jakobsen, Mr Gregor, Mr Šadžius, Mr Parts, Ms Ivanova, Mr Russo, Mr Balko, 
Mr Lehne, Mr Lazarou, Mr Tomé Muguruza, and Mr Milionis. 

 
 
 
 
5 

FOREWORD BY THE SECRETARY-GENERAL: 
THE ECA'S SUSTAINABILITY REPORT 

The  basic  objective  of  corporate  responsibility  is  to  ensure  that  the  activities  of  an 
organisation have a positive impact on society, the environment and the economy. These 
are the three basic pillars on which corporate responsibility, or sustainability, operates. 

Sustainability therefore addresses the ethics of an organisation’s activities, and how it 
operates in a way that is viable over the long term. These two factors – ethics and long-
term  viability –  are  intrinsically  linked,  because  an  organisation  that  damages  the 
systems on which it depends will ultimately become unsustainable. 

In January 2021, I announced the priorities for 2021-2025, with sustainability as one of 
the  key  values  guiding  the  mission  of  the  Secretariat-General.  Today,  I  am  pleased  to 
present our first report on the sustainability of the European Court of Auditors. 

Sustainability reporting is the practice of measuring, disclosing and being accountable to 
internal and external stakeholders for organisational performance towards the goal of 
sustainable  development.  It  covers  the  ways  in  which  an  organisation  considers 
sustainability issues across all of its operations, as well as its environmental, social and 
economic impacts. 

This report provides an overview of the economic, environmental and social impacts of 
our  operations  in  auditing whether  EU  funds  are  supporting  sustainable  and  inclusive 
growth in Europe and across the globe. It also provides information about the impact of 
our structure and the ways in which we operate administratively in order to pursue this 
mission. 

At the European Court of Auditors we are committed to being a sustainable institution 
and for several years already we have been gradually deploying efforts to minimise our 
impact in the environment. Our EMAS certification is tangible proof that our efforts are 
moving in the right direction. 

However,  as  I  already  mentioned,  sustainability  is  more  than  just  greening.  It  is  also 
about economic impact, ethics and governance, respect for laws and regulations and, 
above all, people. Our staff. At the ECA, we consider our staff to be our most valuable 
asset,  and  we  implement  a  whole  range  of  initiatives  and  actions  to  optimise  staff 
wellbeing. Continue reading to find out more about our wellbeing initiatives. 

 
6 

This report has been drafted in accordance with the Global Reporting Initiative standards 
(GRIs), and follows their structure. It is a compliance report, stating facts, and contains 
information intended for the use of our stakeholders, and in particular for EU citizens, on 
how our institution behaves from a sustainable point of view. We trust that readers will 
find  the  information  in  this  report  both  interesting  and  relevant.  We  welcome  any 
comments  or  questions,  which  should  be  sent  to  the  following  email  address: 
alfonso.delafuente@eca.europa.eu. 

For further information on the ECA’s activities and audit reports, please visit our website 
www.eca.europa.eu. You can also: 

  Follow us on Twitter @EUAuditors 

  Check our pages on LinkedIn and Facebook 

  Watch our videos on YouTube: EUAuditorsECA 

Zacharias Kolias 
ECA Secretary-General 

 
 
 
 
 
INTRODUCTION: REPORTING 
PRINCIPLES 

7 

INTRODUCTION: 
REPORTING 
PRINCIPLES 

 
 
 
8 

01 Sustainability  reporting  is  the  practice  of  measuring,  disclosing  and  being 
accountable to internal and external stakeholders for organisational performance, in the 
context of moving towards the goal of sustainable development. It covers the way in 
which  an  organisation  considers  the  impact  of  its  operations  on  the  three  pillars  of 
sustainability: society, the environment, and the economy. 

02 Our  approach  to  sustainability  reporting  is  still  developing.  Our  aim  is  to  report 
according  to  the  EU’s  sustainability  reporting  standards,  which  are  currently  under 
development as part of the draft Corporate Sustainability Reporting Directive (CSRD). In 
the meantime, this our first sustainability report, is a compliance report based on the 
Global  Reporting  Initiative1  (GRI)  standards,  which  describes  the  efforts  that  the 
European  Court  of  Auditors  (ECA)  is  making  in  order  to  be  a  sustainable  institution. 
According to the three pillars of sustainability, it describes the efforts made to address 
the  environmental,  social  and  economic  impact  of  our  audit  and  administrative 
operations,  both  internally  and  externally,  i.e.  how  sustainability  issues  impact  our 
organisation, strategy and work.  

03 The  Reporting  Principles  are  fundamental  in  terms  of  achieving  high  quality 
sustainability reporting. An organisation is required to apply the Reporting Principles if 
it wants to claim that its sustainability report has been prepared in accordance with the 
GRI  Standards.  The  Reporting  Principles  are  divided  into  two  groups:  principles  for 
defining report content, and principles for defining report quality. These principles were 
all taken into account when drafting this report. 

04 The Reporting Principles for defining report content help organisations to decide 
what to include in the report. This involves considering the organisation’s activities and 
impacts,  and  the  substantive  expectations  and  interests  of  its  stakeholders.  These 
principles  are:  stakeholder  inclusiveness,  sustainability  context,  materiality,  and 
completeness. 

05 Stakeholder  inclusiveness  means  that  we  shall  identify  our  stakeholders,  and 
explain how we have responded to fulfil their reasonable expectations and interests. 

06 To comply with the principle of sustainability context, this report shall present our 
performance within the wider context of sustainability. 

1  The Global Reporting Initiative is an international not-for-profit organisation. GRI produces 
free  Sustainability  Reporting  Guidelines  to  enable  companies  and  organisations  to  report 
their economic, environmental, social and governance performance. 

 
                                                      
9 

07 In  sustainability  reporting,  materiality  is  the  principle  that  determines  which 
relevant  topics  are  sufficiently  important  that  it  is  essential  to  report  on  them.  A 
combination of both internal and external factors can be taken into consideration when 
assessing  whether  or  not  a  topic  is  deemed  to  be  material.  These  include  the 
organisation’s  overall  mission  and  competitive  strategy,  and  any  concerns  directly 
expressed by stakeholders. 

08 Materiality can also be determined by broader societal expectations, and by the 
organisation’s 
influence  on  upstream  or  downstream  entities.  Assessments  of 
materiality  are  also  expected  to  take  into  account  the  expectations  set  out  in 
international  standards  and  agreements  with  which  the  organisation  is  expected  to 
comply. 

09 To ensure completeness, the report shall include coverage of material topics and 
their  corresponding  boundaries, 
significant  economic, 
sufficient 
environmental,  and  social  impacts,  so  as  to  enable  stakeholders  to  assess  our 
performance in the reporting period. 

reflect 

to 

10 The  Reporting  Principles  for  defining  report  quality  guide  the  choices  made  to 
ensure  the  quality  of  information  contained  in  a  sustainability  report,  including  its 
proper  presentation.  These  principles  are  accuracy,  balance,  clarity,  comparability, 
reliability, and timeliness. This report follows the exact structure of the GRI standards to 
ensure that these principles are followed. 

11 We are a public institution that does not manufacture physical goods and we do 
not  have  manufacturing  centres  or  supply  chains.  There  are  therefore  a  number  of 
standards and disclosures that do not apply to our institution. Making use of the block 
modular  structure  of  GRI  reporting  standards,  the  replies  to  those  standards  and 
disclosures that have been considered as not applicable to our institution have not been 
included in the report. The list of non-applicable standards and disclosures is included 
in Annex. 

 
 
 
10 

GENERAL 
DISCLOSURES 

 GENERAL DISCLOSURES 

 
11 

Organisational Profile 

12 The  European  Court  of  Auditors  (hereinafter:  ECA)  is  an  EU  institution  whose 
mission is to assess – through its independent, professional and impactful audit work – 
the economy, effectiveness, efficiency, legality and regularity of EU action to improve 
accountability,  transparency  and  financial  management,  thereby  enhancing  citizens’ 
trust, and responding effectively to current and future challenges facing the EU. The ECA 
acts as the independent guardian of the financial interests of the citizens of the Union. 

13 The scope of the ECA’s operations covers all spending on policies and programmes 
in all areas of the EU budget. Our final beneficiaries are the EU’s citizens. 

Figure 1 – The ECA headquarters in Kirchberg (Luxembourg) 

Source: Global View SRL – photographer: Simon Schmitt. Architects of the buildings: Paul Noёl (1988 and 
Jim Clemes (2004 & 2013). 

14 Composed of three main buildings connected by a central corridor, and located in 
Luxembourg, the ECA’s headquarters are our main base for operations. At the end of 
2021,  our  institution  counted  853  permanent  and  temporary  posts,  together  with 
92 contract staff and 25 seconded national experts. 

15 In 2021, our budget amounted to around €153.7 million, with an execution rate of 
97 % (96 % in 2020). Our budget represents around 1.5 % of the EU’s total administrative 
spending (less than 0.1 % of total EU spending). 

 
 
12

16 The  ECA  has  cooperated  with  other  Supreme  Audit  Institutions  (SAIs)  and
international  audit  organisations  since  its  establishment  in  1977.  Within  the  EU,  this 
cooperation  takes  place both bilaterally, with the  SAIs  of t he  27 Member  States, and 
multilaterally, within the framework of the Contact Committee of EU SAIs. This forum 
facilitates dialogue and exchanges between the ECA and the SAIs of EU Member States. 

17 The ECA also supports the SAIs of EU candidate and potential candidate countries
(Albania,  Bosnia  and  Herzegovina,  Kosovo2,  Montenegro,  North  Macedonia,  Serbia, 
Moldova,  Georgia,  Ukraine  and  Türkiye).  The  main  vehicle  for  this  cooperation  is 
the  network  of  the  SAIs  of  candidate  and  potential  candidate  countries,  which 
operates  similarly to the Contact Committee.  

18 The ECA is an active member of the International Organisation of Supreme Audit
Institutions (INTOSAI), and participates in the activities and projects of other INTOSAI 
working  bodies,  notably  on  environmental  auditing  (as  a  member  of  the  Steering 
Committee). 

19 In  1990,  the  ECA  was  one  of  the  30  founding  members  of  the  European
Organisation of Supreme Audit Institutions (EUROSAI), which is the European regional 
arm of INTOSAI. The ECA is actively involved in EUROSAI activities and is the co-leader 
of the project group on “Preparing for future risks and climate crisis: time for audit to 
take  a  long-term  view?” as  well  as  being  an  active  member  of  the  project  group  on 
auditing the response to COVID-19. 

20 The ECA is one of the 25 members of the Global Audit Leadership Forum (GALF), a
forum  for  heads  of  SAIs  that  aims  to  enhance  the  audit  activities  of  member  SAIs, 
address global and strategic issues, and contribute to the INTOSAI community. 

21 The ECA is a member of the Bridge Forum Dialogue, a Luxembourg-based forum
that aims to stimulate discussion on questions concerning Europe, and bring together 
supranational  institutions  and  agencies,  national  institutions,  civil  society, and  the 
academic world. 

2  This  designation  is  without  prejudice  to  positions  on  status,  and  is  in  line  with  UNSCR 

1244/1999 and the ICJ Opinion on the Kosovo Declaration of Independence. 

13 

22 We are a member of Inspiring More Sustainability (IMS3) Luxembourg, a network 
of companies and organisations established in Luxembourg, and having an engagement 
towards corporate social responsibility. Within this framework, the ECA participates in 
a number of projects and committees with IMS (REUSE project following the Zero Single-
Use Plastic Manifesto, Zero food waste, Target Zero Carbon, Eco mobility, etc.). 

Figure 2 – The ECA signed the Diversity Charter Lëtzebuerg 

Source: ECA. 

23 On 14 October 2021, the ECA signed the Diversity Charter Lëtzebuerg, a national 
commitment text proposed for signature to any organisation in Luxembourg wishing to 
commit to diversity promotion and management through concrete actions that go 
beyond solely legal obligations. By signing the Diversity Charter Lëtzebuerg, 
organisations are committing to fighting all forms of discrimination and to setting up a 
policy that favours equal opportunities and diversity, focused on the 
acknowledgement and valuing of individual skills. 

3 

IMS – Inspiring More Sustainability, is an independent, apolitical, non-profit organisation in 
Luxembourg.  IMS  is  the  national  representative  for  CSR  Europe,  the  European  leader  for 
corporate social responsibility. With its corporate members, National Partner Organisations 
and Associated Partners, CSR Europe unites, inspires & supports over 10,000 enterprises at 
local, European and global level. 

 
 
                                                      
14 

Strategy 

24 Our vision is aiming to be at the forefront of the public audit profession, and to 
contribute to a more resilient and sustainable European Union which upholds the values 
on which it is based. 

25 Our  strategy  is  based  on  our mission,  vision  and  values,  and  has three  Strategic 
Goals: 

Figure 3 – ECA’s Strategic Goals 

26 Sustainability  has  been  established  as  a  cross-cutting  issue  in  our  2021-2025 
strategy, which is a public document, and can be consulted in detail in the following link: 
https://www.eca.europa.eu/Lists/ECADocuments/STRATEGY2021-2025/ 
STRATEGY2021-2025_EN.pdf. 

27 The statement by senior management regarding the relevance of sustainability to 
the  organisation  (as  required  by  disclosure  102-14)  is  included  as  a  foreword  to  this 
report. Audit-related work is our core business. Through auditing sustainability action of 
the EU, we can provide information, accountability and impact in terms of how the EU 
responds to the key challenges of our time. Increasing the credibility of information on 
sustainability through audit is one of the challenges for the EU in terms of sustainability 
reporting, that we have identified through our audit work. 

 
 
 
15 

Ethics and integrity 

Values, principles, standards, and norms of behaviour 

28 The ECA as institution has the following five values: 

Figure 4 – ECA values 

Source: ECA. 

o 

o 

Independence:  we  carry  out  our  work  free  from  any  influence  that  may 
compromise, or may be seen to compromise our professional judgement; 

Integrity: we act honestly, reliably and solely in the EU public interest, and aim to 
lead by example in our professional work, and the way in which we manage our 
institution; 

o  Objectivity:  We  are  impartial  and  unbiased,  and  base  our  audit  conclusions  on 

sufficient relevant and reliable evidence; 

o 

o 

Transparency:  we  communicate  our  findings  through  clear,  comprehensive  and 
accessible  reports,  which  are  published 
languages  and  respect 
confidentiality and data protection requirements; 

in  all  EU 

Professionalism: in line with international auditing standards, we acquire, develop 
and maintain the highest levels of knowledge, expertise and skills, related to both 
the public audit profession and EU financial and policy management. 

 
 
16 

29 Our ethical guidelines are based on the INTOSAI Code of Ethics (ISSAI 130). They 
are  in  line  with  the  ECA’s  core  values,  and  are  applicable  to  all  Members  and  staff. 
Former and current Members are also subject to a specific code of conduct. 

Figure 5 – Ethical principles and guidelines 

Source: ECA. 

30 The seven principles of ethical guidelines are: 

(1)  Trust,  confidence  and  credibility:  "Be  aware  of  and  act  in  accordance  with  the 
Court’s ethical requirements. Seek advice on ethical matters where necessary"; 

(2) 

Integrity: "Show integrity and due care in the performance of your duties"; 

(3) 

Independence,  objectivity  and  impartiality:  "Behave  in  a  manner  that  promotes 
confidence in the Court’s independence, objectivity and impartiality"; 

(4)  Professional secrecy: "(…) duty of confidentiality in relation to our work"; 

(5)  Competence  and  further  professional  training:  "Act  always  in  a  professional 

manner and comply with high professional standards"; 

(6)  An excellent and efficient organisation: "contribute to the development of the Court 

as an excellent and efficient organisation"; 

(7)  Good  administrative  conduct:  "apply  the  principles  of  good  administrative 

conduct". 

 
 
17 

31 All staff are subject to the Staff Regulations for Officials of the European Union and 
the Conditions of Employment of Other Servants of the European Union (hereafter the 
Staff Regulations). Among other rules, the staff policy requires all employees to adhere 
to the principle of professional secrecy, the staff rotation policy, the promotion policy, 
and the rules of procedure for reporting severe irregularities. 

32 The Members of the ECA should be independent and free from any circumstances 
that  might  compromise  their  professional  judgement.  Furthermore,  and  in  order  to 
avoid any financial conflicts of interest, all Members are required to sign a declaration 
stating their financial interests, assets, partners' professional activities, and their own 
external activities. 

33 In  addition  to  declaring  their  financial  interests  upon  taking  up  their  duties, 
Members must respect the obligation to behave with integrity and discretion regarding 
the acceptance of any appointment or benefit after they cease to hold office. 

34 Staff  at  the  ECA  are  allowed  to  perform  external  activities,  subject  to  prior 
authorisation  and  as  long  as  they  follow  the  ethical  guidelines  established  for  this 
purpose. 

35 Officials must not accept gifts or other benefits that might influence their duties. 
However,  small  hospitality  gifts  that  are  considered  within  the  bounds  of  normal 
courtesy can be accepted.  

36 During missions that form part of audit tasks, invitations for breakfast, lunches, or 
dinners should be declared in the mission declaration. 

37 The staff policy includes an anti-harassment mechanism. This scheme consists of 
a  support  network  that  includes  confidential  counsellors,  the  Medical  Officer,  line 
managers, the mediation service, and the Human Resources department. Other relevant 
elements are detailed in Box 1: 

 
18 

Box 1 – Elements of the ECA's Staff Policy 

Professional secrecy 

Staff from the ECA are bound by the principle of professional secrecy. They must refrain 
from any unauthorised disclosure of information received in the line of duty, unless that 
information has already been made public or is accessible to the public. They continue to 
the bound by this obligation after leaving the service. 

Staff rotation policy 

The  rotation  of  auditors  across  different  chambers  is  key  to  ensuring  the  quality  and 
objectiveness of the organisations under audit. Employees’ ethical standards and integrity 
are also highly valued when assessing comparative merit for promotions. 

Whistleblowing 

Staff are required to provide information if they witness any illegal activity, fraud, or passive 
corruption in the course of or related to the performance of their duties. They have the 
option of preserving their anonymity. 

38 The  supporting  structure  for  ethical  advice  and  concerns  consists  of  an  Ethics 
Committee, ethics advisers and a Transparency Portal. 

39 Together with the ethics advisers, the ECA Training team has developed a training 
programme  consisting  of  an  ethics  course,  conferences  and  workshops.  With  this 
programme,  the  training  team  aims  to  raise  awareness  on  this  topic  through  annual 
ethics-related events, and provide specific training for the confidential counsellors on 
topics related to harassment. 

40 In addition, a catalogue including ethics courses is offered to newcomers through 
the ASPIRE integration programme for auditors. Ethics-related courses focus on ethics, 
public integrity, whistleblowing, fraud prevention, and principles of good administration 
and audit, while the confidential counsellors receive training on harassment and public 
ethics. 

Governance 

41 The ECA’s top governance structure is the Court, formed by 27 Members, one from 
each EU Member State. Members are appointed for a six-year renewable term by the 
Council of the European Union (Council), in consultation with the European Parliament 
(EP). Members are assigned to an audit chamber, where they adopt audit reports and 
take decisions on broader strategic and administrative issues (see Figure 6). Audit tasks 

 
19 

are performed by ECA staff under the supervision of the chamber's assigned Member. 
The Member presents audit reports for adoption, and then to the EP, the Council and 
other stakeholders. 

42 The  ECA  staff 
in  audit,  translation,  and 
administrative  services,  across  ten  audit  and  administrative  directorates.  The  ECA 
employs nationals from all Member States. 

includes  employees  who  work 

43 The  President  is  selected  from  and  by  the  Members  every  three  years.  The 
president's role is to be "first among equals", to chair the Court meetings, and to ensure 
the adequate implementation of decisions and management of the institution. 

44 The  remuneration  for  ECA  Members  is  established  in  Council  Regulation  (EU) 
2016/300,  which  determines  the  emoluments  of  EU  high-level  public  office  holders. 
They are remunerated at the level of an AD16 official, with a fixed salary that does not 
include  any  clawbacks  or  bonuses,  deferred  or  vested  shares,  or  any  other  form  of 
performance-based pay. Members benefit from a specific retirement pension scheme. 

Figure 6 – ECA governance structure 

Organisation of ECA

5 Audit Chambers
27 Members

PRESIDENCY

AUDIT 
CHAMBERS

SECRETARIAT
GENERAL

Corporate Strategy, 
Planning and Performance 
Management

Institutional 
Liaison

Communication and 
Media Relations

Legal matters

Internal audit

Chamber I 
(Sustainable use of 
natural resources)

Chamber III 
(External action, security 
and justice)

Chamber V
(Financing and 
administering the Union)

Chamber II 
(Investment for cohesion, 
growth and inclusion)

Chamber IV 
(Regulation of markets and 
competitive economy)

Human resources, 
finance and 
general services

Information, 
workplace and 
innovation

Language and 
editorial 
services

ADMINISTRATIVE 
COMMITTEE

AUDIT QUALITY 
CONTROL 
COMMITTEE

ETHICS 
COMMITTEE

INTERNAL AUDIT 
COMMITTEE

Source: ECA. 

 
 
20 

45 Members  are  responsible  for  various  committees:  Audit  Quality  Control, 
Administrative,  Ethics,  and  Internal  Audit  Committees.  They  also  collaborate  in  the 
Foresight  Advisory  Panel.  The  Members  approve  the  ECA’s  values,  objectives  and 
strategy. There is no specific committee responsible for decision-making on economic, 
environmental,  and  social  topics,  as  these  matters  are  delegated  to  the  Secretary-
General. 

Box 2 – Members’ committees 

Audit Quality Control Committee: an oversight body responsible for the ECA’s audit policies, 
standards and methodology, audit support and development and audit quality control. The 
committee is made up of the Member for Audit Quality Control and one Member from each 
Chamber. 

Administrative Committee:  coordinates administrative strategies, monitors and evaluates 
their effect, and is responsible for preparatory work on strategic planning and performance 
management,  prior  to  ECA  decisions.  Composed  of  the  President,  the  Deans  of  the  audit 
chambers, the Member for Institutional Relations and the Member for Audit Quality Control. 

Ethics  Committee:  responsible  for  assessing  the  Members’  outside  activities  and  for 
considering any matter of an ethical nature relevant to the ECA’s reputation. The Committee 
is composed of three members, including one external member. 

Internal Audit Committee: responsible for Internal Audit matters on the Court's behalf. It is 
composed of four members: three Members of the Court and one external expert. 

Foresight Advisory Panel: drives the ECA’s foresight initiative. It develops foresight practice 
and  provides  foresight  advice  based  on  comprehensive  risk  analysis.  It  supports  the 
application of foresight techniques in audit and related knowledge management activities. 

46 Every six years, a Secretary-General (SG) is appointed by the Court. The SG is the 
most  senior  member  of  staff,  to  whom  the  Court  delegates  authority.  The  SG  is 
responsible for the management and administration of: human resources, finance, and 
general  services;  information  technology,  workplace  and  innovation;  translation, 
language  services,  and publication.  The  SG  is  also  responsible  for decision-making  on 
economic, environmental, and social topics. 

47 The sustainability report is prepared by the services of the SG and is approved by 
the Court. Following this first sustainability report, we expect to report on sustainability 
on an annual basis.  

48 There  were  no  critical  concerns  regarding  sustainability  in  2021.  Should  such  a 
situation  arise,  the  SG  would  report  to  the  Court  or  to  the  different  committees, 
depending on the nature of the event. 

 
21 

Stakeholder engagement 

49 The ECA employs a variety of efforts to engage with our stakeholders, which are 
shown in Figure 7: 

Figure 7 – ECA stakeholders map 

European 
Parliament 
and other EU 
institutions

EU and 
international 
audit 
organisations 
and bodies

European 
citizens

Member 
States

OLAF and 
EPPO

Universities 
and schools

Media

Staff Unions / 
USL

Neighbourhood
(Luxembourg Authorities, 
European Parliament, 
Chambre de Commerce, 
Centre Sportif la Coque, 
Kirchberg Funds)

Audited bodies:

Suppliers and contractors:

European 
Commission and 
agencies

Council

Service suppliers 
(IT services, 
canteen, vehicles, 
other)

European 
Parliament

Court of Justice 
of the European 
Union

European 
Investment 
Bank

European 
Economic and 
Social 
Committee

Source: ECA. 

Travel suppliers 
(airlines, etc.)

Building 
maintenance 
contractors

Committee of 
the Regions

External 
auditors

Any other 
auditee 
recipient of EU 
funds

Utilities 
suppliers

IT equipment, 
office materials, 
and furniture 
suppliers

 
 
22 

50 The ECA has teams in charge of internal communication with staff on the one hand, 
and  external  communication  with the  international  press  on the  other.  Our  aim  is to 
keep all staff informed about the latest news both within the ECA and relating to it. We 
also alert stakeholders and press to the most recent activities and events relating to the 
ECA’s work, and seek to maintain external interest in our institution. We make active 
use  of  various  communication  channels,  ranging  from  our  intranet  and  internet 
webpages  to  the  ECA  Journal  and  social  media  (LinkedIn,  Instagram,  Twitter  and 
Facebook), together with press reviews, press releases and briefings. 

51 The ECA has a team charged with fostering institutional relations with two of our 
important stakeholders, namely the European Parliament (EP) and the Council, with the 
aim of developing broader and deeper contacts, and ensuring feedback. 

52 With  regard  to  the  EP,  the  main  objective  is  to  strengthen  relations  with  the 
Budgetary Control Committee (CONT) and other specialised committees for whom our 
work could be relevant. 

53 The ECA has set up a tool called the Stakeholder Management System (SMS), which 
is  used  to  communicate  with  targeted  stakeholders  ranging  from  EU  institutions  to 
Member State authorities and other auditee-level contacts. The SMS also has a dynamic 
'calendar  of  events'  function,  related  to  the  ECA’s  work  and  output,  which  is 
complemented by a reports’ progress forecast tool. 

54 An  indicative  timetable with  a  12-month  projection  of  upcoming  special reports 
and our mission planning is sent to our main stakeholders on a quarterly basis, enabling 
them  to  better  plan  their  work  in  relation  to  our  special  reports.  Giving  our  main 
stakeholders better and more detailed information about the timing of our upcoming 
special reports is essential, as the value of our contribution to EU accountability depends 
on our main partners’ use of our work and products as part of the accountability process. 

55 The European Commission (EC) is our main auditee. To facilitate communication, 
an  annual  meeting  is  organised  between  the  EC’s  Commissioners  and  the  ECA’s 
Members. 

56 In  2021,  we  signed  a  new  tripartite  agreement  with  the  EC  and  the  European 
Investment Bank (EIB), two of our main stakeholders. This agreement allows the ECA 
greater  access  to  EIB  information  relating  to  activities  carried  out  under  the  EC’s 
mandate. 

 
23 

57 The  ECA  ensures  that  its  reports  are  properly  disseminated  to  Member  States’ 
national parliaments, ministries and central governmental bodies. ECA Members visit 
national parliaments and governments on a regular basis to inform them about our work 
and reports. 

58 The EP exercises democratic oversight through the budget discharge procedure, 
which is the main reporting procedure for EU institutions’ accountability. On the basis 
of a recommendation from the Council, and having received the ECA’s annual report and 
its statement of assurance, the EP decides whether or not to grant discharge, i.e. final 
approval of how the budget for a specific year has been implemented. The procedure 
ends  in  discharge  being  granted,  postponed,  or  refused.  The  ECA  is,  as  all  other  EU 
institutions, included in this annual control procedure. 

59 There is currently one agreement between the ECA and the staff unions, which was 
renewed in 2018. All staff are covered by this agreement – see paragraph 108.  

Reporting practice 

60 This  report  has  been  prepared 
in  accordance  with  the  GRI  Standards: 
Comprehensive  option,  as  explained  in  paragraph 02.  The  reporting  period  is  the 
calendar year, in this case 2021, and we intend to follow an annual reporting cycle. As 
this is our first report on sustainability, there are no restatements of information, nor 
any  changes  in  comparison  with  previous  reports  regarding  material  topics  or  report 
boundaries. 

61 No material topics were identified during the process of drafting this report. There 
was no use of external assurance regarding the content of this report. Our contact point 
for  any  questions  relating  to  this  report  is  Mr  Alfonso  de  la  Fuente  Garrigosa 
(contact: https://www.eca.europa.eu/en/Pages/ContactForm.aspx). 

Management Approach 

62 Material  topics  are  those  that  reflect  an  organisation’s  significant  economic, 
environmental  and  social  impact,  or  those  that  substantively  influence  stakeholders’ 
assessments and decisions. 

63 For our institution, no such material topics have so far been identified. Therefore, 
a management approach in this respect has not yet been defined. 

 
 
24 

ECONOMIC 
STANDARDS 

 ECONOMIC STANDARDS 

25 

Economic Performance 

64 As an EU institution, our budget is set out within the EU budget. Other than the 
revenue received from the EU budget, the ECA does not receive any financial assistance 
from any government. The ECA does not generate any revenue in the sense that our 
activities are non-commercial in nature. Regarding the ECA’s expenditure, circa 90 % of 
our  budget  is  spent  on  staff  costs,  missions,  and  other  related  expenditure  (Medical 
Service, canteen, social welfare, etc.). 

65 We do not currently have concrete information on whether climate change poses 
specific risks to our operations, or whether it may create specific opportunities for our 
institution.  Given  the  inherent  complexity  of  the  issue,  we  have  not  carried  out  any 
studies in this regard. 

66 The staff retirement plans are those set by the Staff Regulations for EU officials, 
and the institution has no discretion to modify them. 

Labour market presence 

67 Staff wages are determined by the EU Staff Regulations, and there is no gender 
discrimination. 

68  In comparing entry level wages, the Luxembourg minimum wage breaks down as 
€2 776.05 for skilled workers and €2 313.38 for unskilled workers (as of April 2022). Our 
minimum  entry  wage  corresponds to  that  for  contractual  staff  in  function  group  FG I 
grade 3, step 2, with a monthly salary of €2 780.16. The ECA is therefore situated at or 
above the minimum wage levels provided for under local legislation. 

69 Recruitment at all levels – including senior management, is done from citizens of 
all  EU  Member  States,  through  open  competitions.  We  keep  recruitment  statistics  in 
order  to  ensure  a  certain  degree  of  geographical  balance.  The  latest  figures  from 
February 2022 are shown in Figure 8. 

 
26 

EU population  
(%) 

ECA Employee  
(%) 

Deviation 
(pp) 

15.1 
18.6 
10.6 
13.3 
8.5 
2.6 
2.4 
4.3 
2.3 
2.2 
2.4 
1.5 
0.6 
1.2 
2.3 
0.5 
1.1 
0.4 
n/a 
1.2 
0.3 
2.0 
0.9 
0.1 
3.9 
0.1 
1.3 
0.2 

13.9 
8.8 
6.7 
6.7 
6.4 
6.1 
5.4 
5.4 
4.1 
3.6 
3.4 
3.3 
2.5 
2.5 
2.1 
2.0 
2.0 
1.8 
1.7 
1.7 
1.6 
1.6 
1.3 
1.2 
1.2 
1.1 
1.0 
0.8 

-1.2 
-9.8 
-3.9 
-6.5 
-2.0 
3.5 
3.0 
1.1 
1.8 
1.5 
1.0 
1.8 
1.9 
1.2 
-0.2 
1.5 
0.8 
1.3 
n/a 
0.4 
1.3 
-0.4 
0.4 
1.1 
-2.7 
1.0 
-0.3 
0.6 

Figure 8 – Staff by nationality 

Countries 

France 
Germany 
Spain 
Italy 
Poland 
Belgium 
Greece 
Romania 
Portugal 
Hungary 
Czech Republic 
Bulgaria 
Lithuania 
Finland 
Sweden 
Slovenia 
Ireland 
Latvia 
United Kingdom 
Slovakia 
Estonia 
Austria 
Croatia 
Luxembourg 
Netherlands 
Malta 
Denmark 
Cyprus 

Source: ECA. 

 
27 

Indirect Economic Impacts 

70 We do not specifically support investment in infrastructures and services for the 
local community, as this does not fall under our mandate as a public institution. For this 
reason,  we  have  not  carried  out  a  community  needs  assessment  with  regard  to 
infrastructures and services for the local community. We are, however, involved with 
the local community, as mentioned in our organisational profile4 (see Organisational 
Profile). 

71 The  ECA  has  a  significant,  positive,  indirect  economic  impact  on  the  local 
community,  in  particular  considering  the  number  of  jobs  supported,  the  number  of 
expatriate  families  settling,  and  the  number  of  children  attending  schools  in  the 
community.  Due  to  its  inherent  difficulty,  we  have  not  conducted  a  specific  study  to 
measure this positive impact and translate it into measurable figures. 

societies  and  economic 

72 Long-term  unemployment  is  closely  linked  to  social  economic  imbalances  in 
long-term 
European 
unemployment  is  therefore  key  for  achieving  sustained  social  and  economic  growth 
within  Member  States.  At  the  ECA,  we  generate  a  positive  indirect  economic  impact 
through our audit reports. 

competitiveness.  Addressing 

4  The  ECA  engages  with  local  organisations  such  as  the  Diversity  Charter  Lëtzebuerg,  IMS 

Luxembourg, and the Bridge Forum Dialogue. 

 
                                                      
28 

Figure 9 – UN Sustainable Development Goals covered by ECA special reports in 2021 

•  Climate change 
and agriculture 

•  Making the polluter pay 

Zero hunger 

Good health and  
well-being 

•  Education in 
Emergencies 

•  Education in Emergencies 
•  Gender-equality 

Quality education 

Gender equality 

•  CAP and water 

projects 

Clean water and 
sanitation 

Decent work and 
economic growth 

Industry, innovation and 
infrastructure 

•  Electrical 

recharging 
infrastructure 
•  Europe´s space 

assets 

•  CAP and water 

projects  

Reduced inequalities 

Responsible consumption 
and production 

Climate action 

•  Cross-border programmes 
•  Post-programme 
surveillance 

•  Financing sustainable 

investment 

•  Long-term unemployment 
•  EU co-funded investments 

in tourism 

•  Exchange of tax 
information 
•  Gender-equality 
•  Cross-border programmes 
•  Long-term unemployment 

•  Electrical recharging 

infrastructure 

•  Climate change and 

agriculture 

•  Forestry 
•  Financing sustainable 

investment 

•  Forestry 

•  Rule of law in Ukraine 

Life on land 

Peace, justice and strong 
institutions 

Source: Data collected by ECA; icons obtained from the UN SDGs communications materials website. 

 
 
 
 
 
 
 
 
 
 
 
 
 
29 

73 56 % of all special reports (SR) published in 2021 covered at least one of the United 
Nations' Sustainable Development Goals (SDGs), as shown above in Figure 9. 

74 Half  of  our  SR  published  in  2021  had  a  link  to  SDG  8  (i.e.,  "decent  work  and 
economic  growth"),  SDG  13  (i.e.,  "climate  action"),  and/or  SDG  10  (i.e.,  "reduced 
inequalities), as shown in Figure 10: 

Figure 10 – Percentage of reports with content linked to each SDG 

Source: Data collected by ECA; icons obtained from the UN SDGs communications materials website. 
75 Sustainable Development Goals ensuring social wellbeing and sustained growth, 
e.g. SDGs 8 and 10, are key for achieving long-term social and economic growth between 
Member States. ECA’s special report SR 25/2021 on long-term unemployment addresses 
social economic imbalances in European societies, and advises how to ensure economic 
competitiveness – see Box 3. 

 
 
30 

Box 3 – Special report 25/2021: EFS support to combat long-term unemployment 

Long-term (L/T) unemployment is a persistent problem in the EU labour market. National policies 
are responsible for deciding and implementing measures for reducing L/T unemployment, while 
EU initiatives encourage cooperation between Member States and support their actions. The EU 
employment  strategy  promotes  a  coordinated  high  skilled  and  adaptable  labour  market.  The 
European Social Fund (ESF) is the main financial instrument supporting this framework. During 
the 2014-2020 period, there were €11.4 billion allocated to address L/T unemployment across 
the EU. 

According to the EC, "access to employment" investment priority accounted for approximately 
half  of  ESF  total  spending  on  L/T  unemployment  measures.  This  EFS  priority  is  the  only  one 
specifically addressing L/T unemployment. For this matter, the ECA assessed whether 2014-2021 
EFS  "access  to  employment"  investments  appropriately  addressed  the  needs  of  the  L/T 
unemployed.  

The audit task concluded ESF support reached the L/T unemployed through different types of 
intervention, but measures did not always reflect the scale of the L/T unemployed issue in some 
Member  States.  Overall,  recommendations  to  the  EC  promoted  improvements  for  achieving 
inclusive and sustainable economic growth and employment (SDG 8) and reduced inequalities 
within and among countries (SDG 10). The ECA specifically recommended the EC should insist on 
Member States specifically targeting the L/T unemployed where is particularly high. In order to 
disseminate  good  implementation  practices,  the  audit  concluded  the  EC  should  evaluate  the 
results achieved by ESF "access to employment" to effectively combat L/T unemployment.  

Procurement Practices 

76 The ECA’s procurement is open to all EU companies. In 2021, the ECA purchased 
goods  and  services  totalling  €15 215 515,  of  which  purchases  from  local  suppliers 
amounted to €10 144 812. The percentage of spending on local suppliers is 67 %. 

Anti-corruption 

77 Regarding operations assessed for risks related to corruption, we must distinguish 
between external and internal operations. By external operations, we are referring to 
operations or transactions under the EU budget, which are controlled in the framework 
of our audit work. The ECA adopted in December 2021 an action plan to contribute to 
combatting fraud against the EU budget. Any fraud or suspicion of fraud that comes to 
light during our audit work is communicated to the European Anti-fraud Office (OLAF) 
by  means  of  the  established  cooperation  mechanisms  and  channels  between  both 
organisations.  By  means  of  a  working  arrangement  signed  in  July  2021,  the  ECA  also 
cooperates with the European Public Prosecutor’s Office (EPPO).  

 
31 

78 Regarding internal operations, risk management is a good management practice, 
a  requirement  under  the  Financial  Regulation,  and  a  key  element  of  the  assurance 
mechanisms on which the ECA relies. The ECA risk register for 2021 provides details of 
the risk assessment for identified risks, and includes a description of the impact in case 
of materialisation, as well as the internal controls put in place to mitigate these risks. 

79 Monitoring and recording risk incidents is fundamental in order to ensure that our 
risk  management  framework  works  effectively.  Incident  reporting  shows  where  the 
actual issues of our institution lie, thus helping us to strengthen the internal controls 
and improve our efficiency. Each director makes an annual risk report for their area of 
responsibility.  It  must  be  noted  that  the  ECA  does  not  specifically  assess  the  risk  of 
corruption, but employs a wider notion of risk of fraud. 

80 A risk of fraud is a risk that, if materialised, may result in financial losses and legal 
actions against the organisation. We have identified this risk as concerning the following 
operational risks: 

o 

o 

o 

Ineffectiveness of the Internal Control Framework in the administration: medium 
risk rating, and low risk tolerance; 

Ineffectiveness of the ethical framework, with a medium risk rating and low risk 
tolerance; 

Failures  in  the  management  of  various  aspects  related  to  security  and  data 
protection, qualified with low risk rating, and low risk tolerance. 

 
32 

81 The ECA registers the various incidents related to the quality of work. Figure 11 
provides an overview of all incidents reported in the risk register: 

Figure 11 – Register of risk incidents for 2021 

Risk indicator 

Audit or review delayed by at least three months 

Cases of personal data breaches 

Cases of accidental or unlawful destruction/loss, alteration or access to 
personal data 

Intentional or unintentional release of secure or confidential information 

Litigation cases due to the mismanagement of staff financial rights and 
benefits, e.g. promotions, leaves, allowances, remunerations and 
reimbursements, social security benefits, pensions 

Total number of risk incidents occurred  

Source: ECA. 

Number of cases 

56 % of adopted 
reports had at least 
3 months delay 

4 

5 

2 

1 

12 

82 There  was  a  confirmed  incident  related  to  a  former  member  of  the  ECA.  In 
September  2021,  the  ECJ  handed  down  its  judgment  in  Case C-130/19,  ECA v Karel 
Pinxten, and ruled that Mr Pinxten has breached the obligations arising from his office 
as a member of the ECA, within the meaning of Article 286(6) TFEU. As a sanction, the 
ECJ  declared  Mr Pinxten  to  have  forfeited  two thirds  of  his pension entitlement  with 
effect  from  the  date  of  delivery  of  the  judgment.  Further  to  the  judgment,  the  ECA 
executed this sanction with immediate effect. 

83 With  regard  to  communication  and  training  on  anti-corruption  policies  and 
procedures, we organised 15 different anti-corruption training events in 2021, with a 
total duration of 76 hours. These events were attended by 1 011 participants, of whom 
939 were staff members5. In addition, a dedicated training event was organised for the 
ECA’s Members in April 2021. 

5  This figure shows the cumulative number of attendees. 

 
 
                                                      
ENVIRONMENTAL STANDARDS 

33 

ENVIRONMENTAL 
STANDARDS 

 
 
34 

Energy 

84 The 2021 figures for energy consumption within and outside the institution, 
including the reduction in energy consumption and the energy intensity ratio, are 
displayed in the table below: 

Figure 12 – Energy consumption figures 

Energy consumption in MWh (numbers have been rounded)

2020

2021

Electricity

Heating

WITHIN the organisation

3 687

3 507

-4.9 %
(% change in consumption between 2020 and 2021)

2 965

3 190

+7.6 %

Total energy consumption WITHIN the organisation

6 652

6 697

+0.7 %

OUTSIDE the organisation

Data center

138

150

+8.6 %

Total energy consumption WITHIN and OUTSIDE of the organisation

6 790

6 847

+0.8 %

Source: ECA. 

85 The overall energy consumption increased by 0,8% as compared to 2020. Indeed, 
the total energy consumption fell by 24 % between 2014 and 2021, but increased by 
0,8% between 2020 and 2021 due to overconsumption caused by the prolonged use of 
ventilation systems in the context of the pandemic preventive measures. 

 
 
35 

Water and Effluents 

86 In 2021, the ECA consumed circa 5 372.4 m3 of water. We are equipped with a rain 
water  collection  system  with  a  total  storage  capacity  of  95 m³,  and  therefore  we 
consume not only discharged water. The rain water collected is mainly used for garden 
maintenance. 

87 Every three years, we set ourselves new targets for water consumption and design 
actions  to  limit  our  water  consumption.  We  monitor  our  water  consumption  on  a 
monthly basis with the help of our maintenance contractor, and follow up every water 
leak to identify its cause. 

88 The water-related impacts of our activities are monitored regularly with a detailed 
environmental analysis. A risk analysis is performed for each activity, which assesses its 
impact  level  in  terms  of  severity,  occurrence  and  the  level  of  control  within  the 
institution.  If  the  issue  becomes  significant,  we  propose  actions  to  mitigate  water 
pollution risks. There are no significant water discharge-related impacts to report. 

Biodiversity 

89 The  impact  of  the  activities  of  our  institution  on  biodiversity  is  fairly  limited. 
However, we regularly monitor our impact through a risk analysis, and assess the impact 
in terms of level of severity, occurrence and the level of control. If an issue becomes 
significant, we take action to mitigate any associated risks. 

90 Our main negative impacts currently arise from emissions stemming from our data 
centre and IT equipment, waste management, printing and copying, catering activities 
and supplies, hazardous product storage and management, cleaning services, and the 
ongoing renovation works on our premises. However, we also create positive impacts 
on biodiversity to offset our negative impacts: 

o  Gardening:  no  invasive  plants  are  used,  local  species  are  favoured  whenever 

possible, and no chemical products are used; 

o  We host several colonies of bees on our premises, comprising four beehives, and 

produced our own honey for the first time in 2020; 

 
o 

o 

A community vegetable garden maintained by staff was created in 2022; 

An initiative for staff to plant trees in a local forest is under development. 

36 

Emissions 

91 Since 2014, the ECA has carried out an annual assessment of its greenhouse gas 
(GHG)  emissions  to  monitor  efforts  to  reduce  its  carbon  footprint.  We  measure  the 
direct  and  indirect  emissions  of  our  activities  using  the  Bilan  Carbone®  method,  to 
ensure  consistent  reporting.  We  measure  upstream  and  downstream  activities,  and 
include  business  travel  and  staff  commuting.  The  last  available  data  on  our  level  of 
emissions dates from 2021, where we had total emissions of 7 578 tCO2eq6, compared 
to 10 699 tCO2eq in our 2014 (baseline). 

92 This constitutes a reduction of 3 121 tCO2eq over that period. We are committed 
to  reducing  our  GHG  emissions.  Every  three  years,  we  set  GHG  emission  reduction 
targets, together with an action plan to monitor our progress. 

Waste 

93 The  ECA  does  not  generate  any  waste  from  manufacturing  processes;  waste 
generation  is  the  result  of  our  own  consumption.  Our  last  available  information  is 
for 2021, when a total of 74.4 tonnes of waste were generated, of which 18.46 tonnes 
(25 %) constituted hazardous waste. 

94 Because  we  care  about  minimising  our  waste-related  impact,  waste  generation 
was  reduced  by 62 %  from  2019  to  2021.  In  addition,  our  recycling  rate  has  reached 
59 %, and our sorting rate has reached 82 %. 

6  Equivalent to 6.6 tCO2eq per FTE. 

 
                                                      
37 

2019

+13 %
+2 %
+18 %
+8 %

95 Waste generation is summarised by type of waste in Figure 13: 

Figure 13 – Waste generated 

Gross annual amount
(in tonnes)

hazardous waste

paper and cardboard waste

mixed municipal waste

food waste

-30 %
-46 %
-20 %
-70 %

2021

2018

70

60

50

40

30

20

10

2020
-60 %
-44 %
-57 %
-76 %

Source: ECA. 

Environmental Compliance 

96 The ECA is fully committed to protecting the environment, both in terms of its audit 
activity,  and  in  its  administrative  management.  Compliance  with  environmental  laws 
and regulations is assessed on an annual basis and if a non-conformity issue is identified, 
the  causes are  analysed  in order to remedy  the  issue as  quickly  as  possible.  No non-
conformity issues were identified in 2021. 

97 It should be noted that the ECA has its own environmental management system 
(EMS),  the  aim  of  which  is  to  improve  the  ECA’s  environmental  performance  by 
minimising the impact of its activities on the environment, in particular through more 
efficient use of energy and natural resources, and better waste management. It helps to 
make buildings more functional, economical, and comfortable for staff. 

 
 
38 

98 The  ECA’s  EMS  complies  with  EMAS  III  standards,  and  meets  the  certification 
requirements  of  international  standard  ISO 14001: 2015.  Developed  by  the European 
Commission, the EU Eco-Management and Audit Scheme (EMAS) is a management tool 
for organisations to evaluate, report on, and improve their environmental performance. 
The ECA was officially registered as an EMAS organisation in 2017, and since then the 
reduction of our environmental impact has been tangible: our energy consumption has 
fallen, our carbon footprint has improved, and our paper consumption has significantly 
decreased. 

Figure 14 – Beehives and apiculture activities by the ECA beekeepers club 

Source: ECA. 

Supplier Environmental Assessment 

99 The ECA’s purchases of goods and services have an impact on the environment, 
which is measured by our carbon footprint. We are committed to green procurement 
by: 

o  Monitoring  our  procurement  procedures 

to  ensure 

that 

they 

include 

environmental award criteria, and subsequently increase their weightings; 

o 

Providing  training  on  green  public  procurement  for  all  departments  involved  in 
procurement procedures; 

o  Making  sure  our  procurement  procedures  are  assessed  by  a  Green  Public 
Procurement  Helpdesk.  This  is  an  interinstitutional  external  contractor  that 
provides  support  for  procurement  units  and  staff  who  deal  with  procurement 
procedures,  to  help  them  integrate  green  criteria  into  all  stages  of  their 
procurement procedures. 

 
 
 
39 

SOCIAL 
STANDARDS

 SOCIAL STANDARDS 

 
40 

Employment 

100 Regarding  hires  and  employee  turnover,  in  2021,  we  recruited  80  new 
employees,  comprising  16  officials,  21  temporary  staff,  30  contract  staff  and 
13 seconded  national  experts.  On  the  other  hand,  51  employees  left  the  ECA,  of 
whom 31  were  officials,  6 temporary  staff,  12 contract  staff  and  2 seconded  national 
experts. 

101 The ECA  has  a  well-developed, broad  wellbeing  policy,  as  shown  in  Figure 15. 
Rather than describing all the different aspects of our wide-ranging wellbeing policy in 
full detail, including the various initiatives derived from it, we will instead focus on the 
information requirements of GRI reporting. 

Figure 15 – ECA wellbeing map 

n
o
i
s
u
l
c
n

i

d
n
a
y
t
i
s
r
e
v
D

i

Emotional

Cognitive

Physical  
nourishment

Physical 
comfort

ECAfit

Physical 
fitness

MENTAL

PHYSICAL

Environmental

Social

SOCIAL

WELLBEING 
AT WORK

Source: ECA. 

 
 
 
 
41 

102 Temporary and part-time employees are provided with the same benefits as full-
time employees; the exception is for seconded national experts, as they are considered 
as  seconded  from  their  national  administrations,  and  therefore  benefit  from  the 
employment conditions in their national administrations. 

103 The right to parental leave is an individual right that cannot be refused, and is 
enshrined in Article 42a of the Staff Regulations. A guide on parental leave procedures 
is available to staff, with details on the application conditions. 

104 Staff are entitled to parental leave during the first 12 years following the birth or 
adoption of their child, from a minimum duration of one month, to a maximum of six 
months. This can be extended to one year in the case of single parents, or parents with 
dependent children who have a disability or a severe illness recognised by the Medical 
Officer. 

105 During parental leave, the staff member’s social security scheme continues, and 
officials retain their post and are entitled to advance to a higher step in their career, or 
be promoted in grade. Annual entitlements are reduced proportionally. Staff may not 
engage in any other gainful employment during this time. 

Labour/Management Relations 

106 The  dialogue  regarding  labour/management  relations  goes  through  a  staff 
committee,  which  plays  a  key  role  in  addressing  staff  issues.  The  staff  committee  is 
composed of eight staff members (plus eight substitutes), who are directly elected by 
staff  every  three  years.  Elections  are  free,  and  any  member  of  staff  may  stand  for 
election, either individually or as part of a staff union.  

107 The framework agreement between the ECA and the staff unions, represented 
by Union Syndicale Luxembourg (USL), was first signed in 1993. This agreement includes 
a clause for tacit renewal every five years, unless one of the parties requests a review 
with  a  three-month  notice  period –  see  paragraph 135.  The  agreement  was  last 
renewed in June 2018. 

 
42 

Occupational Health and Safety 

108 To  contribute  to  achieving the  ECA’s  strategic  objectives,  the SG  establishes a 
strategic development plan for staff, workplace and services for a period of five years. 
Objectives are associated with the notions of wellbeing, mutual respect, and physical 
and mental health. The strategic development plan is implemented on an annual basis 
through annual work programmes. These actions help us improve the safety and health 
conditions for our staff at the workplace. 

109 Our  health  and  safety  system  complies  with  local  legislation,  in  particular 
Luxembourg’s labour law and the law on buildings. It covers all buildings and activities, 
all staff, and visitors. 

110 The security and safety incidents are handled by the security and safety service 
in collaboration with the buildings department. We have specific internal guidelines for 
the following incidents: 

o 

o 

o 

o 

Fires, storms, and evacuation of the premises; 

Accidents (first aid); 

Incidents involving elevators; 

Security threats, including guidelines for security and the safety of our staff while 
travelling on mission. 

111 Dedicated IT tools allow us to send instant alerts and preventive messages to all 
staff  in  case  of  any  major  incident.  We  have  identified  the  following  work-related 
hazards that pose a risk of serious injury: 

o 

Fire and external threats (e.g. attacks), including during missions; 

o  Maintenance and working on buildings. 

112 These have been identified through a risk management process, and the results 
are  compiled  in  a  register  of  the  most  critical  risks.  Other  operational  hazards  are 
identified  through 
legal 
requirements, recommendations and benchmarking. Through this process, hazards that 
pose a risk of serious injury have been addressed by the relevant ECA departments. The 
Strategy Development Plan addresses these risks and proposes mitigation measures. 

feedback  analysis,  events, 

interviews,  on-site  visits, 

 
43 

113 In 2021 there were only four7 minor injury-related incidents, and no major injury-
related incidents. 

114 Staff have direct access to the security and safety service in the event that they 
identify a risk. An intranet ticketing system allows staff to report issues on security and 
safety. Certain sensitive risks (for example, psychological risks) are covered by specific 
guidelines: 

o 

o 

o 

Specific  procedures  to  protect  against  the  risk  of  reprisals,  as  described  in  an 
internal decision on our policy of maintaining a satisfactory working environment 
and combating psychological and sexual harassment; 

A  specific  anti-harassment  procedure,  in  force  and  available  to  all  staff  on  the 
intranet; 

There is a network of ethics advisers that any member of staff has the right and 
opportunity  to  consult  in  order  to  seek  confidential  and  impartial  advice  with 
regard to the following: 

  The  values  and  principles  expected  of  staff  (e.g.  independence,  integrity, 

impartiality, professionalism); 

 

Specific sensitive matters, such as actual or apparent conflicts of interest, or 
accepting gifts; 

  Providing information in the event of serious irregularities (whistleblowing). 

115 Our occupational health and safety system includes a Medical Service for all staff, 
headed  by  a  Medical  Officer.  Medical  Service  employees  have  signed  a  medical 
confidentiality clause. The ECA offers the following medical services to its staff: 

o 

o 

Free annual medical check-up and follow-up; 

Compulsory medical check-ups before recruitment; 

o  Medical emergencies, including ambulance service, ambulatory treatment during 
working hours and, if needed, transport to hospital by the emergency services; 

o 

Psychological counselling, with up to ten sessions reimbursed per year; 

7  These minor injury incidents were as follows: subcontractor (dust in eye); ECA staff member 
(wounded finger); ECA staff member (fall down stairs); subcontractor (wounded finger). 

 
                                                      
44 

o 

o 

o 

o 

o 

o 

o 

o 

Possibility of on-site physiotherapy; 

Annual  ophthalmological  check-up,  including  the  reimbursement  of  glasses  for 
work; 

Personalised advice on ergonomics for all staff when setting up their workstation, 
including adjustable desks and adapted IT equipment; 

Free mammography for women over the age of 40 every two years; 

Annual reimbursed gynaecological smear test; 

Flu  vaccination  campaigns  for  all  staff  on  a  voluntary  basis,  and  other  free 
vaccinations; 

Advice on returning to the workplace after long-term sick leave; 

Assistance  from  the  Medical  Officer  for  staff  who have  to  travel  to  countries 
outside Europe, including recommendations on essential vaccinations and advice 
on hygiene risks. 

116 In response to the COVID-19 pandemic, the ECA has taken all steps necessary to 
protect  its  staff  and  ensure  a  safe  working  environment.  This  includes  contact 
prevention  measures,  free  on-site  PCR  tests,  free  rapid  antigen  test  kits,  and  free 
distribution of protection materials for staff, such as surgical and FFP2 masks and alcohol 
sanitiser gels. 

117 We take the promotion of staff health very seriously, and we aim to help all our 
staff to lead rich lives, enjoying good health and with the energy to take on challenges 
at work and live life to the full. 

118 The ECA facilitates employee’s access to a number of health services and health 
prevention programmes, including: 

o 

Free in-house health check-ups, as well as more extensive preventive examinations 
in hospital; 

o  During  the  COVID-19  pandemic,  intranet  announcements  on  practically  a  daily 

basis, with information on how to be safe in the workplace; 

o 

Psychological help for staff; 

 
45 

o 

A wellbeing working group for staff, and wellbeing initiatives, e.g. good practices 
and recommendations for managers and staff on continuous teleworking, work-life 
balance and  wellbeing practices.  An  intranet page  on wellbeing  groups  together 
these initiatives and keeps staff informed; 

o 

Communication  campaigns  on  the  “Right  to  disconnect”  and  “Respect  in  the 
Workplace”, and free morning mindfulness sessions for all staff; 

o  Webinars and workshops on work-life balance, focusing on families and parental 

life. 

119 We  offer  free  and  payable  sports  and  health  activities:  gym,  sauna,  ECA  Fit 
programme with different sports activities and classes, and an outdoor sports ground. 
Furthermore, the staff canteen and cafeteria promote a balanced diet. We also offer 
staff the possibility to take a sabbatical, family, parental, or special leave, or make use 
of hybrid teleworking arrangements. 

120 The staff consultation process on health and safety issues is carried out by means 
of  the  joint  committee  on  Health,  Safety,  Catering  and  Wellbeing  at  work.  This 
committee was set up in 2017 and meets twice per year. 

121 Our annual training programme offers different types of training on health and 
safety  issues.  This  training  is  available  for  workers  and  covers  various  fields  (Fire 
Marshals, first aid course, Hostile Environment Awareness training, crisis management 
and resolution training). Training on wellbeing at work is also available to staff. 

122 Since we have not collected specific data on work-related ill health figures, to 
measure  this  topic  we  have  used  the  absentee  rate.  Data  for  the  last  three  years  is 
shown in Figure 16: 

Figure 16 – Absentee rates 

2019

2020

2021

4.2 %

5 %

4

3

2

1

0

Source: ECA. 

3.2 %

The total absentee rate 
has decreased since 2019, 
despite the current 
pandemic crisis.

 
 
46 

123 The total absentee rate has decreased since 2019, despite the current pandemic 
crisis. 

Training and Education 

124 The  average  training,  broken  down  by  year  and  by  employee,  is  recorded 
according to the number of days, and takes into account the type of employment (audit 
or non-audit) and gender. Language training courses are not included in these statistics. 
The data for 2021 are displayed in Figure 17: 

Figure 17 – Average number of training days per employee in 2021 

Female

Male

9.5

Audit

7.7

4.6

Non audit

4.3

Source: ECA. 

125 Our programmes for upgrading employee skills and talent management include: 

o 

o 

o 

o 

o 

A  broad  catalogue  of  internal  training  courses,  as  well  as  funding  support  for 
external training or educational schemes. Our training also includes a large annual 
selection  of  in-house  conferences,  seminars  and  practice-sharing  sessions,  on  a 
wide  variety  of  subjects,  not  solely  related  to  audit  topics,  but  also  wellbeing, 
current issues, IT matters, ethics, etc.; 

Support  for  obtaining  and  maintaining  professional  qualifications  (ACCA,  CIA, 
CGAP, etc.), and cooperation with a wide range of academic institutions, including 
a Master’s degree programme provided by an external university in the workplace; 

Training for staff to become members of different support groups and networks 
(ethics  advisors,  confidential  contact  counsellors,  career  advisors,  mentors,  and 
internal facilitators); 

An  internal  scheme  for  short-term  secondments  within  the  cabinets  of  ECA 
Members and the Secretariat-General; as well as external secondment schemes to 
other Supreme Audit Institutions or international organisations, such as the IMF; 

EU  fellowship  programme:  one  semester  at  a  selected  university  in  the  United 
States, Brazil, Asia, Australia, Italy or the UK, acting as EU ambassadors; 

 
 
 
47 

o 

o 

o 

ECA  staff  participation  in  Public  Investment  Management  Assessment  (PIMA) 
missions organised by the IMF; 

Performance Recognition Awards, which are granted every year to staff who have 
demonstrated exceptional competence in their work; 

Knowledge Management Awards, which are granted every year to staff who have 
contributed to making the ECA a knowledge-based organisation; 

126 A more detailed description of our training activities can be found in our training 
catalogue and annual training work programme, which are available to all staff on our 
intranet. 

127 We offer staff transition assistance programmes, including: 

o 

o 

o 

Exit interviews; 

Information offered to staff by Human Resources; 

Inter-institutional pre-retirement training and a new ‘active seniors’ scheme. 

128 All  staff,  including  contract  staff,  receive  mandatory  annual  performance  and 
career  development  reviews  on  a  compulsory  basis –  except  for  Seconded  National 
Experts  from  Member  State  administrations –  who  can  however  participate  on  a 
voluntary basis. 

 
48 

Diversity and Equal Opportunity 

129 Overall, we employ equal proportions of women and men in our workforce – see 
Figure 18: 

Figure 18 – Proportion of men/women in our workforce 

Auditors and 
administrators

Assistants and 
secretaries

Management

53 % 47 %

33 % 67 %

64 % 36 %

Male

Female

587
total posts

Source: ECA. 

61

294

130 We are committed to offering equal career opportunities for our staff at all levels 
within the institution. In 2008, the ECA set up a Joint Committee on Equal Opportunities 
(COPEC), whose mandate was renewed and expanded in 2018. In particular, COPEC was 
mandated with monitoring the implementation and impact of the ECA’s Action Plan on 
equal opportunities, as well as proposing measures and actions with a view to complying 
with the requirements of the Staff Regulations. 

131 We employ equal proportions of women and men, and more than a third (36 %) 
of  our  directors  and  principal  managers  were  female  in  2021  (35 %  in  2020).  The 
proportion of  female principal  managers  in  audit  at  the  ECA  reached  37.5 %  (29 %  in 
2020), which is close to our 2027 target of 40 %. With our new multiannual policy and 
action plan for 2021-2025, we moved from an equal opportunities policy to a broader 
in  2021.  Similarly,  we  remain  committed  to 
diversity  and 
geographical balance in our management. 

inclusion  approach 

132 There are no differences in our remuneration policies between women and men. 

 
 
49 

Non-discrimination 

133 In 2021, no incidents relating to discrimination against staff were identified or 
reported. 

Freedom of association and collective bargaining 

134 Staff  at  the  ECA  enjoy  freedom  of  association.  In  2018,  the  ECA  renewed  its 
framework  agreement  with  the  staff  unions,  represented  by  Union  Syndicale 
Luxembourg (USL), to represent staff rights. This framework agreement was first signed 
in 1993, and renewed in 2018. 

135 By  signing  this  agreement,  the  parties  confirmed  their  wish  for  freedom  of 
association  for  ECA  staff.  The  agreement  also  comprises  a  consultation  mechanism, 
which normally involves three phases. The objective is to reach an agreement during 
any one of these phases, which are as follows: 

o 

o 

o 

In a first (administrative) phase, aiming to carry out a technical examination of data 
in the file, the consultation takes place at the level of the competent department 
within the Administration; 

In a second (technical) phase: consultation with the Director of Human Resources; 

In a third (political) phase, and if necessary, consultation is done with the SG. 

136 The  agreement  also  regulates  the  role  and  functions  of  the  staff  unions  and 
conciliation procedures, together with the staff’s right to strike. 

Child labour, forced or compulsory labour, rights of indigenous 
peoples 

137 We  have  not  identified  any  operations  that  present  any  significant  risks  for 
incidents  of  child  labour,  or  incidents  of  forced  or  compulsory  labour  relating  to  our 
operations, or those of our suppliers. 

138 In the course of our operations, we have not detected any incidents of violations 
involving the rights of indigenous peoples. 

 
50 

Security Practices 

139 There is no specific training for security personnel on human rights policies or 
procedures. However, there are internal guidelines on taking into account human rights, 
which  are  available  to  security  agents  to  help  them  to  maintain  their  awareness  of 
respect for human rights. Members of our security staff are instructed to comply with 
human rights guidelines. 

Human Rights Assessment 

140 Our operations have not been subject to specific human rights reviews or impact 
assessments, given the nature of our work. It has not yet been considered necessary to 
organise specific employee training on human rights policies or procedures. 

141 Due  to  the  nature  of  our  procurement,  we  have  not  yet  developed  specific 
human  rights  clauses  to  be  included  in  our  procurement  policies,  nor  do  our  public 
procurement procedures undergo specific human rights screening. 

Local Communities 

142 We do not currently carry out any operations that have a significant actual or 
potential negative impact on local communities. 

Supplier Social Assessment 

143 The  ECA’s  general  procurement  conditions  specifically  provide  for  compliance 
with  the  applicable  labour  and  social  legislation.  Green  Public  Procurement  (GPP) 
criteria are included in the technical specifications, selection and award criteria for our 
public procurement procedures, in accordance with our Environmental Policy. However, 
the policy does not provide for social aspects. 

144 The  application  of  the  GPP  criteria  does  not  include  social  aspects  per  se. 
However,  for  certain  types  of  service  procurement  procedures  (cleaning  services  or 
catering), social aspects may be taken into consideration and assessed at the same time 
as environmental aspects. For instance, the use of ethical and fair trade products, which 
certify that people working all along the supply chain enjoy fair working conditions, is 
assessed along with the labels and certifications. Further checks are performed by the 
Medical Service regarding the safety of cleaning products used. For the companies that 

 
51 

provide  cleaning  services,  the  applicable  salary  index  is  checked  to  ensure  that  the 
contractor pays its employees adequately. 

145 We  are  not  aware  of  any  negative  social  impact  within  our  supply  chain. 
However, we have not carried out specific research in this respect.  

Public Policy 

146 As a public institution, and considering its role and mission, the ECA does not 
participate in implementing public policy development (although our audit reports do 
contribute  to  public  policy  development).  The  ECA  does  not  carry  out  any  lobbying 
activities. 

Customer Health and Safety 

147 Due to the nature of its audit operations, the ECA does not carry out assessments 
of the health and safety impact of products or services, as we are not a manufacturing 
organisation.  Therefore,  no  incidents  were  reported  relating  to  non-compliance  of 
operations in terms of customer health and safety. 

Socioeconomic Compliance 

148 In  2021,  we  did  not  identify  any  non-compliance  issues  in  our  institution  in 
connection with laws and regulations in the social and economic domain. 

 
 
52 

ANNEX 

This annex lists the disclosures that were considered not applicable to our institution, 
due to our nature and characteristics as a public organisation: 

o  Disclosure 102-9 Supply chain 

o  Disclosure 102-10 Significant changes to the organisation and its supply chain 

o  Disclosure 102-21 Consulting stakeholders on economic, environmental, and social 

topics 

o  Disclosure 102-28 Evaluating the highest governance body’s performance 

o  Disclosure 102-38 Annual total compensation ratio 

o  Disclosure 102-39 Percentage increase in annual total compensation ratio 

o  Disclosure 202-2 Proportion of senior management hired from the local community 

o  Disclosure 203-1 Infrastructure investments and services supported 

o  Disclosure 203-2 Significant indirect economic impacts 

o  Disclosure 206-1 Legal  actions  for  anti-competitive  behaviour,  anti-trust,  and 

monopoly practices 

o  Disclosure 207-1 Approach to tax 

o  Disclosure 207-2 Tax governance, control, and risk management 

o  Disclosure 207-3 Stakeholder engagement and management of concerns related to 

tax 

o  Disclosure 207-4 Country-by-country reporting 

o  Disclosure 301-1 Materials used by weight or volume 

o  Disclosure 301-2 Recycled input materials used 

o  Disclosure 301-3 Reclaimed products and their packaging materials 

o  Disclosure 302-2 Energy consumption outside of the organisation 

o  Disclosure 302-5 Reductions in energy requirements of products and services 

 
53 

o  Disclosure 303-2 Management of water discharge-related impacts 

o  Disclosure 303-3 Water withdrawal 

o  Disclosure 303-4 Water discharge 

o  Disclosure 304-1 Operational  sites  owned,  leased,  managed  in,  or  adjacent  to, 
protected areas and areas of high biodiversity value outside protected areas 

o  Disclosure 304-3 Habitats protected or restored 

o  Disclosure 304-4 IUCN Red List species and national conservation list species with 

habitats in areas affected by operations 

o  Disclosure 305-6 Emissions of ozone-depleting substances (ODS) 

o  Disclosure 305-7 Nitrogen oxides (NOX), sulphur oxides (SOX), and other significant 

air emissions 

o  Disclosure 306-1 Waste generation and significant waste-related impacts 

o  Disclosure 306-2 Management of significant waste-related impacts 

o  Disclosure 417-1 Requirements for product and service information and labelling 

o  Disclosure 417-2 Incidents  of  non-compliance  concerning  product  and  service 

information and labelling 

o  Disclosure 417-3 Incidents 

of 

non-compliance 

concerning  marketing 

communications 

o  Disclosure 418-1 Substantiated  complaints  concerning  breaches  of  customer 

privacy and losses of customer data 

 
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doi:10.2865/986032

ISBN 978-92-847-8909-2