Stellungnahme DK zum ESMA-Konsultationspapier: ESMA Guidelines on Alternative Performance Measures
The disclosure of APMs may promote an improved understanding of companyperformance. In order to meet this objective, these APMs need to be presented in an intelligible and meaningful format. In light of the above, we basically subscribe to ESMA’s objective of improving transparency, consistency and comparability in the presentation of the APMs. However, we are doubtful whether the proposed Guidelines on Alternative Performance Measures will achieve this objective.
Furthermore, we hold the view that the definition of the scope of application is not sufficiently unambiguous and that it is clearly excessively far-reaching. Furthermore, the ESMA should fine-tune the objective of the paper with a view to cost-benefit aspects. In our opinion, there is no urgent need for a review of the existing CESR recommendations (CESR(05-178b). […]