• Frankfurt, 17 June 2025

Benchmarks Applied in DMA – Interview with MCG exploring integrating impact intensity benchmarks in DMAs

Interview with Gaia Cimbro – Mitsubishi Chemical Group

 

In the evolving landscape of sustainability reporting, companies are increasingly looking for ways to refine their Double Materiality Assessment process. We spoke with Gaia Cimro from our member company Mitsubishi Chemical Group about their innovative approach to integrating benchmark data into the DMA framework for bringing greater objectivity and first attempts of thresholds to this exercise.

1. What motivated you to start an exercise to explore benchmark integration into the DMA process?

Our DMA outcomes had primarily been driven by qualitative insights and focused largely on our own operations. While useful, this approach lacked the breadth and quantitative aspect needed for a full understanding of our value chain impacts. To bridge this gap, I began integrating benchmarks specifically for value chain topics. This provided a much-needed quantitative layer to complement our existing qualitative assessments.

2. Can you walk us through how benchmarks were layered onto your existing assessment? Did the benchmarks challenge your initial materiality assumptions?

We adopted a triangulated methodology: comparing qualitative results from stakeholder workshops with quantitative data from Input-Output (IO) modelling and then validating these against external benchmarks. This revealed areas where our initial assumptions required adjustment. For example, a topic rated as “highly material” during a workshop was found to be “not material” through IO modelling and only “slightly material” based on benchmark data. In such case, we reclassified the final assessment to reflect this more nuanced view. The process ultimately helped us refine our materiality judgments with greater confidence.

3. This was a new and exploratory approach – what technical or conceptual challenges did you face?

One major challenge was the absence of benchmark data for certain topics, biodiversity being a key example. Additionally, there was uncertainty around whether using our operational revenue as a scaling factor for upstream impacts was methodologically sound. We also encountered difficulties aligning existing indicators with CSRD topic requirements, which sometimes lacked one-to-one correspondence.

4. Where did benchmarking reveal surprising insights – either in areas where MCG outperformed or lagged global peers?

Benchmarking yielded particularly valuable insights in areas that are usually challenging to assess qualitatively. For instance, waste in the upstream value chain emerged as an insightful and measurable indicator. Benchmarks on fair wages and human rights also stood out as they allowed us to pinpoint impact hotspots across our supply chain that would have been difficult to identify through qualitative methods alone.

5. Looking back, what would you say were the most valuable learnings from this exercise in terms of improving materiality assessment and communication to stakeholders?

The experience demonstrated how impact valuation can be practically applied in a corporate setting, grounding the DMA process in tangible, data-driven insights. It brought real added value to a process that is often seen very complex. Moreover, it aligned well with topics that are already embedded within corporate sustainability teams, enhancing both internal decision-making and external communication. It also helped us articulate our findings to stakeholders in a clearer way.

6. Although still experimental, do you see this benchmark-enriched approach becoming part of your official CSRD reporting? What would need to happen internally or externally to support that transition?

Absolutely. This approach has strong potential to enhance our CSRD reporting, especially by providing justifications for non-material topics and offering deeper insights into where impacts occur within the supply chain. For full integration, we first need to foster a more advanced understanding of impact valuation internally. From there, we must communicate these insights effectively to external report users. Ultimately, formal validation by our auditor will be critical to ensuring that this methodology meets regulatory expectations.

 

Conclusion

MCG’s experience shows that benchmark integration can add accuracy and clarity to the DMA process. While challenges remain, particularly around data gaps and methodological alignment, this approach offers a promising path forward for companies aiming to enhance their materiality assessments with impact valuation in line with CSRD requirements.

 

By: Magdalena Wottke, Value Balancing Alliance e.V.