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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: 17 April 2020 - onwards
Version 2 of 2

Question 17: Application of the Fair review principle to APMs; Paragraphs 6, 8 and 22 of the APM Guidelines. (updated 17 April 2020)

Question 17: Application of the Fair review principle to APMs; Paragraphs 6, 8 and 22 of the APM Guidelines.

Date last updated: October 2017

Question: May APMs representing a biased measure of performance (i.e. a measure that includes one-off gains but disregards one-off related losses) violate the APM Guidelines even if they are correctly labelled?

Answer: In accordance with paragraph 8, the APM Guidelines are based on the principle stated in Articles 4 and 5 of the Transparency Directive of providing a fair review of the development and performance of the business and the position of the issuer. In addition, the overall objective of the APM Guidelines, as prescribed in paragraph 6 of the Guidelines, is to contribute to transparent and useful information to the market and improve comparability, reliability and/or comprehensibility of APMs used.

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