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ECOBIO WHITEPAPER 02/2022

EU Taxonomy Classification
and Reporting in 2023
EIGHT STEPS FOR COMPLIANCE

For companies in the non-financial sector

We help you balance business and nature.


Aims and Limitations

This whitepaper aims to provide implementation


guidance on EU Taxonomy Classification and Reporting
requirements valid from 2023. The document deals with
the actions needed by companies in the non-financial
sector.

Disclaimer
The information and guidance in this
whitepaper are intended to contribute to
a better understanding of EU Taxonomy
classification and reporting requirements.
This whitepaper is intended purely as a
guidance tool – only the text of the
Taxonomy Regulation (2020/852/EU),
Climate Delegated Act (EU) 2021/2139,
Commission Delegated Regulation
(2021/2178/EU), and Non-financial
Reporting Directive (2014/95/EU) have
legal force. Ecobio is not responsible for
the use which might be made of the
following information. As this guidance
reflects state of the art at the time of its
drafting, it should be regarded as a 'living
tool' open for improvement, and its
content may be subject to modifications
without notice.

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ECOBIO WHITEPAPER 02/2022

EU Taxonomy Classification
and Reporting in 2023
EIGHT STEPS FOR COMPLIANCE

Contents
1. What is the EU Taxonomy Regulation?
2. Which companies are required to act now?
3. Eight steps for compliant EU Taxonomy classification and
reporting from 2023
4. Ecobio Manager – The world's most comprehensive digital
solution for EU Taxonomy
5. Ecobio Taxonomy services

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1. What is the EU Taxonomy Regulation?
The EU Taxonomy Regulation and The EU Taxonomy Regulation (2020/852/EU)
related statutes direct investments and its delegated acts' sets technical screening
towards sustainable economic criteria to determine if an economic activity can
activities. They formulate a robust be considered sustainable for six environmental
and science-based framework for objectives.
companies and investors that The technical screening criteria are currently
provides environmental criteria for available for the two objectives: climate change
determining which economic mitigation and climate change adaptation. The
activities substantially contribute to criteria for the remaining objectives are
the EU Green Deal objectives. expected to be published in 2022.

Companies should classify their The essential legal documents are


economic activities complying with Regulation (EU) 2020/852 (Taxonomy
the substantial contribution criteria, Regulation)
do-no-significant-harm Climate Delegated Act (EU) 2021/2139
requirements and minimum social Disclosures Delegated Act (EU) 2021/2178
safeguards, and report on the key Non-Financial Reporting Directive
performance indicators (KPIs) (2014/95/EU)
related to the Taxonomy-aligned supported by
activities. the guidance document FAQs (1/2022) and
the draft Commission notice (2/2022) on the
interpretation of certain legal provisions of
the Disclosures Delegated Act.
Environmental objectives for economic
activities defined in the EU Green Deal
Definitions of Taxonomy concepts
Climate change mitigation Economic Assessment unit in
Activity Taxonomy methodology
Company Non-financial undertaking
Climate change adaptation

NACE European Classification


Sustainable use and protection of Economic Activities
of water and marine resources
Substantial Positive impact on the
Contribution environment

Transition to circular economy DNSH Do No Significant Harm


Minimum Minimum social guidance
safeguard
Pollution prevention and control KPI Key performance
indicator

Protection and restoration of


CapEx Capital expenditure
biodiversity and ecosystems OpEx Operational expenditure

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2. Which companies are required to act now?

The Taxonomy Regulation (2020/852/EU) Timeline of Taxonomy reporting


requirements
applies to the financial sector and
companies, which are subject to the
obligations of publishing a non-financial 12.7.2020
statement on a company or group level. The Taxonomy Regulation
Companies that are subject to non-financial enters into force
reporting obligations, also have reporting
obligations under the Taxonomy Regulation.

2022
EU rules on non-financial reporting currently
Companies report
apply to large companies and public-interest
Taxonomy-eligibility for the
entities with more than 500 employees. This previous calendar year
covers approximately 11 700 large
companies and groups across the EU,
including
During 2022
listed companies
Technical Screening Criteria
banks
for the remaining
insurance companies environmental objectives
other companies designated by national expected to be published
authorities as public-interest entities.

In 2022, the listed companies with over 500 2023


employees should report the proportion of
Taxonomy-eligible activities as turnover, Companies report eligibility
and alignment with the EU
capital expenditures, and operational Climate Delegated Act for the
expenditures related to their economic previous calendar year
activities in the year 2021.

The eligibility reporting helps companies to 2024


prepare for their Taxonomy alignment
disclosures. In 2023, companies should Companies report eligibility
and alignment of all
report their turnover, CapEx and OpEx in
environmental objectives for
relation to the environmentally sustainable the previous calendar year
economic activities that align with the EU
Taxonomy criteria defined in the Climate
Delegated Act.

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3. Eight steps for compliant EU Taxonomy
reporting in 2023
The Taxonomy work process can be In 2022, the Taxonomy classification
divided into classification and reporting and reporting requirements are
sections. The process starts by creating limited as companies shall only
a list of economic activities and disclose the share of Taxonomy-
assessing Taxonomy-eligibility. If an eligible and Taxonomy non-eligible
economic activity is included in a economic activities in their turnover,
delegated act, i.e. Taxonomy-eligible, it CapEx and OpEx.
means that this activity can make a
substantial contribution to one or more In 2023, the companies are required
environmental objectives under the to disclose the proportion of their
Taxonomy Regulation. turnover, CapEx and OpEx
associated with economic activities
If your company's economic activity is that qualify as environmentally
eligible, you shall continue to assess the sustainable according to the
alignment of your economic activity classification requirements and the
with the Taxonomy requirements. technical criteria (Figure 1).
Finally, you need to define the key
performance indicators by economic Companies shall report information
activity, combine the financial data with as part of their non-financial
the classification data, and disclose the statement following Article 19a of the
results. Non-Financial Reporting Directive
(2014/95/EU).

Taxonomy-Eligible
Economic Activity

Substantially contribute
to minimum one of the
environmental objectives
Reporting Taxonomy eligibility
Taxonomy alignment
requirements KPIs - Turnover, CapEx, OpEx
Do no significant harm
to any of the other
environmental objectives

Comply with
Minimum social safeguards

Figure 1. The elements of EU Taxonomy classification and reporting in 2023

The eight-steps outlined on the following pages will help you fulfil
the actual Taxonomy requirements in your company.

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Eight steps for compliant
EU Taxonomy reporting

Step 1: Gather your Taxonomy team

Step 2: Identify your Taxonomy-eligible economic activities

Step 3: Classification - Substantial contribution

Step 4: Classification - Do no significant harm

Step 5: Classification - Minimum safeguards

Step 6: Define turnover, CapEx and OpEx

Step 7: Compile Accompanying Qualitative Information

Step 8: Disclose the Taxonomy-aligned activities in KPIs


and Accompanying Qualitative Information

As a result, your company complies with Taxonomy Regulation and you


will be able to disclose the KPIs of your company's activities associated
with environmentally sustainable economic activities.

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Step 1: Gather your Taxonomy team:
professionals in finance, sustainability,
and legal affairs

The Taxonomy classification and


reporting require a work team of The process leader
professionals in finance,
sustainability, and legal affairs. The tends to be a financial
team should have a deep
or sustainability
understanding and experience in
environmental issues, accounting, professional.
and compliance.

THE ROLES IN A TEAM CAN BE, FOR EXAMPLE:

Professionals in Professionals in Legal professionals


sustainability finance Assess compliance
Classify economic Report KPIs' primary with legal
activities data and disclosure requirements

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Step 2: Identify your potential economic
activities and assess Taxonomy-eligibility
The first task of your team is to The Taxonomy activities are linked
identify potential economic activitiesto the NACE codes in the
of the company by using the defined Taxonomy system. You can use
list of Taxonomy activities. that linkage with assessing the
Companies shall identify each eligibility of your economic
economic activity, including a subset activities. In practice, using only
of transitional and enabling the connections of the NACE
economic activities (2021/2178/EU). codes will hide many
environmentally sound economic
A dialogue between team activities under more extensive
professionals is needed to determine activities, and you will disclosure
a reasonable or even possible level too low eligibility.
of non-financial reporting during the
reporting period. Remember that the The assessment of eligibility of
economic accounting systems are economic activities is not
not prepared for Taxonomy dependent on the accounting
classification. standards used (FAQs, 1/2022).

The Climate Delegated Act provides Companies that do not have


a set of Taxonomy activities defined eligible economic activities should
as critical for climate change therefore disclose the information
mitigation and climate change that is required in relation to their
adaptation. Study if your company non-eligible economic activities
has any activities that can be eligible (FAQs, 1/2022).
with those definitions of Taxonomy
activities. Some examples of the
NACE codes, Taxonomy activities,
and economic activities are
presented in Table 1.

Table 1. An example of economic activities

Your economic activity NACE code Taxonomy activity


A business unit of wind 28: Manufacture of Manufacture of renewable
power technology machinery and equipment energy technology
Solar power farm 35.11: Production of Electricity generation using
electricity solar photovoltaic technology
HQ, real estate 68: Real estate activities Renovation on existing
renovation buildings

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Taxonomy classification -
The assessment of environmentally
sustainable economic activities
Taxonomy classification defines As of January 2023, all six
which economic activities are environmental objectives are
environmentally sustainable. expected to be applicable and at
least the climate change objectives
Taxonomy-eligible activities need to be evaluated for
constitute a group of activities that alignment:
have a potential to align with the
Taxonomy criteria. You need to climate change mitigation,
identify all the projects and sites etc. climate change adaptation,
involved in the eligible activities and sustainable use and protection
cluster them by the type of activity. of water and marine resources,
After the eligible activities are transition to a circular
identified, it is possible to assess the economy,
Taxonomy-aligned activities that pollution prevention and
companies are required to disclose control,
in 2023. protection and restoration of
biodiversity and ecosystems.
Taxonomy Regulation sets out three
conditions that an economic activity
must meet to be recognised as
Taxonomy-aligned:
The classification
making a substantial contribution
to at least one environmental process is explained in
objective, steps 3-5 on the
doing no significant harm to any
other environmental objective, following pages.
complying with minimum social
safeguards

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Step 3: Classification
- Substantial contribution
The first part of the Taxonomy classification is to assess the substantial
contribution criteria. For an economic activity to be Taxonomy-aligned and
defined as environmentally sustainable, it must meet strict conditions, of
which the first one is to make substantial contribution to at least one of the six
environmental objectives.

For this purpose, at first your team needs to assess which criteria apply to
your activity. Note that transitional and enabling activities can also make
substantial contribution.

The activity must comply with the Taxonomy technical screening criteria. It is
important to check the threshold of each activity. Depending on the activity,
you must assess the compliance with the relevant legislation when required,
and e.g., calculate GHG emission or LCA.

An example of substantial contribution criteria

Economic Taxonomy
Substantial contribution criteria
activity activity

GHG emissions (calculated in


accordance with Regulation (EU)
Production of 3.11 Manufacture of
2019/331) from the carbon black
carbon black carbon black
production processes are lower than
1,141 tCO2e per tonne of product

4.1 Electricity
Electricity
generation using The activity generates electricity using
production
solar photovoltaic solar PV technology
site x
technology

5.5. Collection and All separately collected and


Collection of transport of non- transported non-hazardous waste that
furniture for hazardous waste in is segregated at source is intended for
reuse source segregated preparation for reuse or recycling
fractions operations

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Step 4: Classification
- Do no significant harm
The second part of the Taxonomy You must check for which
classification is to assess the do no environmental objectives you
significant harm criteria (DNSH). need to assess DNSH and you
There is a particular difference need to check DNSH activity by
between requirements for ‘substantial activity. When assessing DNSH, it
contribution’ and ‘doing no significant is required to consider the full life
harm’. To be recognised as cycle of the products and services
environmentally sustainable activity, that the economic activity
companies must ensure that the provides. You should take into
economic activity that substantially consideration the environmental
contributes to environmental impacts of the economic activity
objectives, does not at the same time itself and the environmental
have a significant negative impacts of the production, use
environmental impact. Companies and end of life of the products
must look in two directions when and services.
considering how an activity is
contributing to one objective and at The Climate Delegated Act
the same time does not do harm to defines criteria for all activities
any other objectives. what it means to do no significant
harm. You also need to assess
compliance with the required
legislation and environmental risk
assessement.

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Step 5: Classification
- Minimum safeguards
The last part of the Taxonomy Companies must comply with the
classification requires companies to principle of ‘do no significant
assess whether their social policies harm’ also with the social
respect the minimum social guidance, resulting in that
safeguards. The aim is that on top of neither the environmental nor
the environmental requirements, the social objective is
undertakings are required to ensure significantly harmed.
that they meet the conditions set out
in basic human rights and labour
standards.

The assessment of social safeguard


compliance is needed on a company
level. In practice, this means that the
company has implemented
procedures that are aligned with

the OECD Guidelines for


Multinational Enterprises,
the UN Guiding Principles on
Business and Human Rights,
the ILO declaration on the
Fundamental Principles and Rights
at Work,
the eight fundamental conventions
of the ILO on human and labour
rights,
the International Bill of Human
Rights, and
the principles set out in the
European Pillar of Social Rights.

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Step 6: Define turnover, CapEx and
OpEx of the Taxonomy-aligned
economic activities
In 2022, companies disclose only The information shall be provided at
information of Taxonomy-eligible the company level where that
and Taxonomy non-eligible company prepares individual non-
activities for environmental financial statements or at the group
objectives of climate change level where the company prepares
mitigation and climate change consolidated non-financial
adaption - while avoiding double statements.
accounting.
Companies should report all their
As of January 2023, companies economic activities. Companies that
shall disclose the proportion of do not have eligible economic
Taxonomy-aligned economic activities need to disclose required
activities in their information related to their non-
total turnover, eligible activities, that is the
capital expenditures and proportion of non-eligible activities
operating expenditures, in turnover, CapEx and OpEx or
including accompanying qualitative equivalent statement (FAQs 1/2022).
information (2021/2178/EU).

Total turnover, CapEx,


and OpEx are interpreted
in more detail on the
following pages.

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Total turnover
Companies shall disclose the Net turnover means the amounts
proportion of turnover derived derived from the sale of products
from products and services and the provision of services after
associated with the taxonomy- deducting sales rebates and value-
aligned economic activities. added tax and other taxes directly
Intangibles shall be included linked to turnover (The Accounting
(2021/2178/EU). Directive, 2013/34/EU).

On a basis of the turnover key If your company has an economic


performance indicator (KPI), it is activity that contributes to several
possible to view a company’s environmental objectives, the
contribution to the environmental turnover can only be calculated
goals. once from that activity in the
numerator of KPIs to avoid double
The turnover KPI should be accounting.
calculated based on the same
accounting principles that apply to
preparing the company’s financial
statements (FAQs, 1/2022).

Turnover of Taxonomy-aligned
The proportion activities (numerator)
of turnover =
* 100%
Total net turnover (denominator)

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Capital expenditures

The CapEx KPI provides a forward- The numerator equals the part of
looking view of companies' plans to the capital expenditure included
transform their business activities to in the denominator that is either
align with the environmental objectives. related to assets or processes
Companies are required to disclose the that are associated with
proportion of their capital expenditure Taxonomy-aligned economic
related to assets or processes activities,
associated with either taxonomy- part of the CapEx plan, or
aligned economic activities or activities related to the purchase of
that are part of a plan to extend or output from Taxonomy-
reach taxonomy-alignment (CapEx aligned economic activities
plan). and individual measures
enabling the target activities
CapEx should be based on the same to become low-carbon or to
accounting principles that apply to the lead to GHG reductions,
company's financial statements. provided that the measures
are operational within 18
The denominator shall cover additions months.
to tangible and intangible assets during
the financial year.
CapEx (2021/2178/EU) shall cover costs
that are accounted for based on
Property, plant, and equipment (IAS
16)
Intangible assets (IAS 38)
Investment property (IAS 40,
several points)
Agriculture (IAS 41)
Leases (IAS 16)

Please check the details from the IFRS


or GAAP principles.

CapEx of Taxonomy-aligned
The proportion activities (numerator)
of CapEx = * 100%
Total Net CapEx (denominator)

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The CapEx plan shows commitment

CapEx plan (2021/2178/EU)


The CapEx plan is strategically important and
requires a high-level commitment as it has to be
approved by the company management board.

The CapEx plan describes how to


expand the undertaking's Taxonomy-aligned
economic activities OR
upgrade Taxonomy-eligible economic
activities to render them Taxonomy-aligned
within five years (maximum 10 years if the
taxonomy criteria are amended).

The CapEx plan shall be disclosed at an


economic activity aggregated level. Companies
are required to disclose the key information
about each of their CapEx plans, including which
economic activities are included in the plan.

Companies must disclose any material changes


that have occurred in the CapEx plan in the
reporting period and the reasons underlying
those changes.

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Operating expenditures

Companies shall disclose the The numerator equals the part of the
proportion of operating operating expenditures included in
expenditures related to assets or the denominators that are either
processes associated with
taxonomy-aligned economic related to assets and processes
activities or to the CapEx plan. associated with Taxonomy-
aligned economic activities,
The denominator shall cover direct including training and other
non-capitalized costs that relate to human resources adaption needs,
research and development, and direct non-capitalized costs
building renovation measures, that represent research and
short-term lease, maintenance and development,
repair, and any other direct part of the CapEx plan, or
expenditures relating to the day- related to the purchase of output
to-day servicing of assets of the from Taxonomy-aligned
property, plant and equipment economic activities and individual
that are necessary to ensure the measures enabling the target
continued and effective use of activities to become low-carbon
such assets. or to lead to GHG reductions,
provided that the measures are
operational within 18 months
(2021/2178/EU).

Where the operating expenditure is


not material for the business model
of the company, the numerator can
be disclosed zero in certain
conditions (2021/2178/EU).

OpEx of Taxonomy-aligned
activities (numerator)
The proportion
of OpEx
= * 100%
Total Net OpEx (denominator)

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Step 7: Compile accompanying
qualitative information

Companies shall disclose the Assessment of compliance with the


accompanying qualitative Taxonomy Regulation
information about the calculation
and key elements of KPIs. See Describe the nature of the
detailed guidance from the Taxonomy-eligible and Taxonomy-
Disclosures Delegated Act aligned economic activities and
(2021/2178/EU). explain how compliance with
technical criteria is assessed.
Accounting policy Companies also need to explain how
they avoided double accounting
Companies shall explain: across economic activities.
1. How turnover, capital
expenditures, and operating More information is needed to
expenditures were determined disclose if your company has an
and allocated to the numerator. economic activity that contributes to
2. The basis on which the turnover, several environmental objectives,
capital expenditures and and also if production facilities are
operating expenditures were used in an integrated manner.
calculated, including any
assessment in the allocation of Contextual information about
revenues or expenditures, to turnover KPI, CapEx KPI and OpEx
different economic activities. KPI
Companies must also include:
references to the related line Companies need to explain the
items, figures for turnover, CapEx, and
information about any material OpEx. You must provide a
changes in the CapEx plan. quantitative breakdown of the
numerators of turnover, capital
expenditures, and operational
expenditures. The changes in KPIs
are also relevant to disclose as well
as key information about each of the
CapEx plans. Explain the other
expenditures relating to day-to-day
servicing of items of property plant
and equipment that are included in
the calculation of OpEx.

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Step 8: Disclose Taxonomy-aligned
activities in the KPIs and Accompanying
Qualitative Information
In 2023, companies with more than Consolidated non-financial
500 employees should disclose their statements disclosures should be
information on turnover, capital based on the same consolidation
expenditures, and operating principles that apply to the groups’
expenditures of economic activities, financial reporting under applicable
which were Taxonomy-aligned in the accounting principles to ensure
calendar year of 2022 or in the fiscal comparability of this reporting with
year ending 2023. the group’s financial information.
(FAQs, 1/2022)
Companies are required to disclose
the turnover, Capex and OpEx KPIs
for each environmental objective and
the total KPIs for all environmental At the moment, there is NO
objectives at the company or group requirement in Union Law to
level. Make sure to avoid double verify the content of the
counting. disclosure, but the proposed
Corporate Sustainability
You shall at first identify the Reporting Directive (CSRD)
proportion of the Taxonomy-eligible would change the status (FAQs;
economic activities. Then within the 1/2022)
Taxonomy-eligible economic activity,
you should identify the proportion of An example of reporting Taxonomy-
that activity that is Taxonomy- aligned activities in 2023 is illustrated
on the next page.
aligned, and the proportion of the
activities that do not meet technical
screening criteria (i.e. that are not
taxonomy-aligned).

You shall provide the information


using the templates presented in
Annex II of the Disclosures Delegated
Act.

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An example of reporting Taxonomy-
aligned activities in 2023

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4. Ecobio Manager – The world's most
comprehensive digital solution for EU
Taxonomy classification and reporting

Turn the complex EU Taxonomy


requirements into a smooth and
straightforward work process
94%
with Ecobio Manager of our customers would
recommend our services.
(Based on a customer satisfaction study
made in 2021 among all Ecobio customers.)
Taxonomy classification
Six environmental
objectives Benefits for your team
Substantial contribution
assessment Comprehensive and up-to-
Do no significant harm date regulatory content
(DNSH) assessment Consolidated classification
Minimum safeguards and key performance
assessment indicators (KPIs)
Upcoming expansions and
KPI reporting updates
A company or group level Document management for
Turnover, capital & assurance
operational expenditures Always available
CapEx plans Advisory services
Qualitative information Open APIs
Detailed disclosure model
by the Delegate Act
Annual reporting

FIND OUT MORE

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The taxonomy-aligned information In addition to the classification of
activities, the EU Taxonomy Regulation
shall be disclosed in digital format
demands companies to track legislation
according to the upcoming changes and demonstrate compliance.
Corporate Sustainability Reporting The Taxonomy Regulation is in force but
Directive (CSRD). will continue to develop in the coming
years. The legislation underlying the do-
no-significant-harm and legislation and
The efficient process starts from
guidelines relating to social responsibility
identifying potential economic
will continue to evolve.
activities. Our Ecobio Manager guides
your team through the classification
Integration with your company’s
and KPI reporting requirements. It also
accounting systems
provides a systematic and documented
Ask for our API connections for the
compliance process that helps the
accounting system of your company.
assurance.

Ecobio Manager creates a smooth work process for the Taxonomy


classification and reporting requirements

Manage EU Taxonomy with Ecobio Manager

Contact sales for further enquiries


about Ecobio Manager services.

Email: sales@ecobiomanager.com Ida Riikonen Malena Weurlander

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Taxonomy Consulting Services
Interpretation of EU Taxonomy criteria
Classification and reporting

EU Taxonomy Expert services for Life Cycle Assessment (LCA)


compliance assessment climate change for EU Taxonomy
Interpreting Taxonomy Interpretation of climate Capable of showing evidence of
criteria change requirements in Substantial GHG- emission
Identifying activity-specific EU Taxonomy savings
requirements Compliance Can be externally verified as
Optimising boundaries of assessments of EU required by the Taxonomy
economic activity for Taxonomy requirements regulation
classification process Environmental and Based on facts and natural
Assessing compliance with climate risk assessment science
the assist of Ecobio Manager Planning the climate Builds on material- and energy
Reporting assessment in and environmental balances
detail into Ecobio Manager transition Covers greenhouse gas emissions
Checking KPI data and (GHG)
consolidation rules Systematic (ISO 14067)

To hear more about Ecobio consulting services for EU Taxonomy


classification and reporting, contact our senior consultants.

PLEASE CONTACT US:

Katrine Hoset, Terhi Valtonen,


PhD, Senior Consultant, Ecobio Senior Consultant, Ecobio

katrine.hoset@ecobio.fi terhi.valtonen@ecobio.fi
+358 20 756 2306 +358 20 765 6144

WE HELP YOU BALANCE BUSINESS AND NATURE

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