The EU Taxonomy Regulation is a uniform, binding system for classifying economic activities according to their environmental sustainability. Companies are obliged to report on the results of this classification on an annual basis. Article 9 of the EU Taxonomy sets out six environmental objectives. Concrete requirements (technical criteria) for environmental sustainability already exist for the first two of these (“climate change mitigation” and “climate change adaptation”) (Commission Delegated Regulation (EU) 2021/2139). Reference will be made to these later on.
Article 8 of the EU Taxonomy Regulation in conjunction with section 289b(1) of the HGB requires United Internet to report in accordance with the EU Taxonomy.
For the 2021 reporting period, it must be established whether economic activities performed by United Internet are described in the annexes to Commission Delegated Regulation (EU) 2021/2139 (“Taxonomy eligibility”). The EU Taxonomy refers both to activities relating to United Internet’s core business areas (e.g., data processing using data centers) and to investments and operating expenditure that are not directly linked to its core business areas (e.g., in relation to passenger cars and buildings).
Consequently, in the EU Taxonomy’s first year of application only the proportion of Taxonomy-eligible and Taxonomy non-eligible economic activities in the Company’s revenue, capital expenditure (CapEx), and operating expenditure (OpEx) must be disclosed. The EU Taxonomy can be construed in different ways in many areas and is currently leading to different assessments and interpretations when it comes to determining Taxonomy eligibility. For example, the expansion of its fiber-optic network, 5G, and the use of its own fiber-optic networks are among United Internet’s core economic activities. However, there is no consensus opinion yet to whether these activities fall within the meaning of economic activity 8.2 “Data-driven solutions for GHG emissions reductions,” and they are therefore assessed differently by companies. As a general principle, the interpretations used in United Internet’s analysis stick closely to the wording and the Company has therefore not classed these activities as Taxonomy-eligible in the first instance. However, the EU Taxonomy’s dynamic environment may lead to different assessments next year.
See ESMA 32-63-1186
United Internet has examined all Group segments for Taxonomy-eligible activities. It did this by analyzing Taxonomy eligibility on the basis of the descriptions of the activities for the two environmental objectives of “climate change mitigation” (Annex 1) and “climate change adaptation” (Annex 2) and of the services offered in the segments. In a next step, the assessments were then discussed in detail with the segments. As a result, the following economic activities in Annex 1 have been identified as Taxonomy-eligible for the 2021 reporting period:
Activity 8.1 “Data processing, hosting and related activities” is the most relevant activity for United Internet in relation to the EU Taxonomy. United Internet’s Business Applications Segment offers domains, home pages, web hosting, servers, cloud solutions and e-shops, group work, and online storage, among other things. This segment’s offering is therefore responsible for the majority of Taxonomy-eligible activities. The Consumer Applications Segment is home to United Internet’s consumer applications such as online storage and personal information management. Activities relating to activity 8.1 have also been identified in this segment. In addition, the Consumer Access Segment also has a small number of Taxonomy-eligible activities within the scope of 8.1 in the form of its online storage offering.
The volume of activities covered by the description of the activity is currently still open to interpretation. For this reason, United Internet has identified those activities (such as online storage) in which hosting and data storage play a key role as Taxonomy-eligible activities for the 2021 reporting period. Other activities merely involving data transfer have not been reported under activity 8.1 for the 2021 reporting period.
Above and beyond this, only those hosting and data storage activities that are performed in the Company’s own data centers have been regarded as Taxonomy-eligible. In other words, hosting and data storage activities that are performed in third-party data centers are not regarded as Taxonomy-eligible. Since it was not possible to make assignments at the level of individual transactions, the proportion of Taxonomy-eligible revenue was determined using an allocation key. The allocation was based on the ratio of electricity used by the Company’s own data centers to that used by third-party data centers. Electricity consumption serves here as an indicator of the volume of data processing performed (IT load). In a first step, electricity consumption by the Company’s own data centers was adjusted up front for the power usage effectiveness (PUE) factor in order to avoid distorting the allocation. This enabled an efficiency-adjusted IT load that is comparable to that for the third-party data centers to be used as a metric. This total amount is systematically analyzed and disclosed under the ISO 50001 energy management system standard that is used to certify our own data centers. The approach minimized any distortions resulting from differences in energy efficiency levels between the Company’s own and third-party data centers.
In addition, horizontal issues and infrastructure-related topics were identified. For example, the Group performs Taxonomy-eligible activities relating to activities 6.5 “Transport by motorbikes, passenger cars and light commercial vehicles” and 7.7 “Acquisition and ownership of buildings”
United Internet’s activities were also examined to determine whether they relate to the environmental objective of “climate change adaptation” (Annex 2). A detailed examination revealed that, in individual cases, activities could be allocated to this environmental objective, e.g., in connection with preventing flood damage where new data centers are built. However, the costs for this are already captured in the CapEx figures under Annex 1. The second FAQs dated February 2, 2022 (Draft Commission Notice) state that the KPIs do not have to be disclosed separately for the two environmental objectives in the initial reporting period. As a result, all figures for revenue, CapEx, and OpEx have been disclosed without breaking them down by environmental objective.
See FAQs Draft Commission Notice, page 11 item 10
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