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Questions and answers on ESMA Guidelines on Alternative Performance Measures (APMs) (ESMA32-51-479 / ESMA32-51-370) (updated 1 April 2022)I. BackgroundII. PurposeIII. StatusIV. Questions and answersV. Legislative references & Abbreviations (updated 1 April 2022)Question 1 Applicability of ESMA's Guidelines on Alternative Performance Measures (APMs) to prospectuses comprising documents published before and on/after 3 July 2016.Question 2: Measures presented simultaneously inside and outside financial statements; Paragraphs 4, 17 and 19 of APMs Guidelines.Question 3: Financial measures calculated using exclusively figures stemming from financial statements; Paragraphs 4, 17 to 19 of the APMs Guidelines.Question 4: Interim financial reports; Paragraphs 3 and 4 of the APMs Guidelines.Question 5: Segment information; Paragraphs 17 to 19 of the APMs Guidelines.Question 6: Labels used on APMs; Paragraphs 22 and 25 of the APMs Guidelines.Question 7: Concept of "corresponding previous periods"; Paragraph 37 of the APMs Guidelines.Question 8: Interim financial statements; Paragraph 31 and 32 of the APMs Guidelines.Question 9: Concept of Prominence; Paragraph 35 and 36 of the APM Guidelines.Question 10: Compliance by reference; Paragraph 45 and 46 of the APMs Guidelines (not applicable to prospectuses which are covered by a separate regime).Question 11: Definition of an APM; Paragraph 17 to 19 of the APMs Guidelines.Question 12: Definition of APMs; Paragraph 17 of the APM Guidelines.Question 13: Scope of the APM Guidelines; Paragraphs 17 to 19 of the APM Guidelines.Question 14: Application of the scope exemption; Paragraph 19 of the APM Guidelines.Question 15: Definition and basis of calculation; Paragraph 20 of the APM Guidelines.Question 16: Reconciliation; Paragraph 26 and 28 of the APM Guidelines.Question 17: Application of the Fair review principle to APMs; Paragraphs 6, 8 and 22 of the APM Guidelines. (updated 17 April 2020)Question 18: Application of the APM Guidelines in the context of COVID-19 Paragraphs 8, 17-19, 33, 34, 41 and 43 of the APM Guidelines.Question 19: Application of the APM Guidelines to measures related to ESG matters; Paragraphs 3, 4, 17, 21, 22, 26, 33, 35, 37 and 41 of the APM Guidelines.Question 20: Labels used by issuers on ESG financial measures; Paragraphs 3, 4, 8, 17, 22, 33 of the APM Guidelines.
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Version date: 31 December 2016 - onwards

Question 2: Measures presented simultaneously inside and outside financial statements; Paragraphs 4, 17 and 19 of APMs Guidelines.

Question 2: Measures presented simultaneously inside and outside financial statements; Paragraphs 4, 17 and 19 of APMs Guidelines.

Date last updated: January 2017

Question: Paragraph 4 of the APMs Guidelines excludes from its scope the APMs disclosed in the financial statements (as defined in section II). Do the APMs Guidelines apply to APMs simultaneously presented inside and outside financial statements?

Answer: Yes. The APMs Guidelines apply to all financial measures which fall within the definition set out in paragraphs 17 to 19 of the APM Guidelines and are disclosed outside financial statements but in documents within the scope of regulated information.

The definition of an APM excludes from its scope financial measures defined or specified in the applicable financial reporting framework. Therefore, financial measures (e.g. subtotals or totals) which are not defined or specified in the applicable financial reporting framework fall under the scope of application of the APMs Guidelines irrespective of whether these financial measures are also disclosed in financial statements.

Where APMs directly identifiable from financial statements are also disclosed outside financial statements, the issuer or the persons responsible for the prospectus:

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