Responsibility Policy: What Should It Contain, and Is It Legally Required?

Note: This article describes Danish legal requirements specifically, under the Danish Financial Statements Act.

The responsibility policy — often called a CSR policy or ESG policy — is no longer only something large, publicly listed companies deal with. More and more small and medium-sized businesses are met with requirements or expectations around responsibility, from customers, partners, and potential buyers of the business alike.

What is a responsibility policy?

A responsibility policy describes how your business works in a structured way with environmental, social and governance matters — often gathered under the abbreviation ESG (Environment, Social, Governance). The policy serves both as an internal management tool and as external documentation when customers, partners or investors ask for it.

Is it legally required to have a responsibility policy?

For the vast majority of small and medium-sized businesses, the answer is no. The statutory requirement for a statement on corporate social responsibility under Section 99a of the Danish Financial Statements Act generally only applies to large businesses in accounting class C and large publicly listed businesses. If your business doesn't fall into that category, a responsibility policy is a voluntary tool — but one increasingly in demand in practice, partly because larger customers and partners are themselves subject to requirements that lead them to pass similar requirements on to their suppliers.

If your business is instead covered by Section 99a, or you're approaching the thresholds that trigger future sustainability reporting under the EU's CSRD rules, a responsibility policy is a natural — but not in itself sufficient — foundation for the mandatory reporting. If you're unsure whether your business is covered, you should clarify it with an accountant.

How should a responsibility policy be structured?

A good responsibility policy follows a logical order, making it easy to read and easy to build on:

• 1. Purpose and scope: Why do you have the policy, and who and what does it apply to?
• 2. Management ownership and responsibility: Who owns the policy internally, and who is responsible for ensuring it's followed?
• 3. Social matters and working conditions: Working environment, employee rights and diversity.
• 4. Environment and climate: Resource consumption, waste and any climate impact.
• 5. Governance, business ethics and anti-corruption: Good corporate governance and compliance.
• 6. The supply chain and partners: What do you expect from your suppliers?
• 7. Concrete goals and actions: Measurable initiatives, not just good intentions.
• 8. Transparency, follow-up and documentation: How do you follow up, and how do you share progress?
• 9. Approval and review: Who has approved the policy, and when is it reviewed again?

It's an advantage to keep the three classic ESG areas — social, environmental and governance — grouped together and separate from each other, rather than mixing them with purpose and documentation early in the document. This makes the policy easier to navigate, both for you and for an external party assessing it.

Why can it make a difference when selling a business?

A documented responsibility policy can in practice strengthen your business's attractiveness to a buyer. More professional buyers — particularly private equity funds and larger strategic buyers — are increasingly incorporating ESG matters as part of their due diligence, and a business that already has this in order comes across as more professionally run and less risky to take over. Conversely, the absence of any responsibility thinking whatsoever can, in certain industries and with certain buyer types, be perceived as a weakness, even though it's not a legal requirement.

Should the policy also cover your supply chain?

It's not a requirement for smaller businesses, but it's an increasing expectation, particularly if you supply larger customers who pass requirements on through their own supply chain. Even a simple statement that you expect similar principles from your most important suppliers can be enough to meet that expectation without making the policy unnecessarily heavy.

Frequently asked questions

Does my business need a responsibility policy?

Only if you're covered by the statutory requirement in Section 99a of the Financial Statements Act — which only applies to large businesses. For everyone else, it's voluntary, but increasingly a good idea.

Is a responsibility policy the same as a mandatory CSR statement?

No. The policy is an internal and external communication tool. A mandatory statement under Section 99a has specific, formal requirements for content and placement in the annual report, which the policy alone doesn't satisfy.

Can a responsibility policy affect the price if I sell my business?

Indirectly, yes — particularly with professional buyers who incorporate ESG matters into their assessment. It's rarely the deciding factor alone, but it can strengthen the overall impression of a professionally run business.

Want a free template for your own responsibility policy? Download it under Documents (currently in Danish), or book a no-obligation call if you'd like help adapting it. If you're unsure how well your business actually lives up to its own policy, you can also do the responsibility check — a free 6-step self-assessment.