does my company need a diversity policy for the questionnaire

Policy or figures only: two separate questions in the VSME

The question of whether your company has a diversity and inclusion policy is separate from the question about the male-female distribution. In the VSME basic module, personnel information is located under the section on labour forces: numbers, types of contract, the male-female distribution within the workforce and the like. These are factual data, not a policy question. Whether there must also be a separate, documented diversity and inclusion policy is a different matter: the basic module primarily asks for the figures, not for a policy document. Many client questionnaires add that policy question themselves, separate from what the VSME strictly requires — comparable to how questions about accident figures are often asked separately. have a policy for health and safety at work often separate from the accident figures.

If you have no separate diversity policy, then "no" is the factually correct answer here — not "no, therefore bad". Many clients ask this purely for inventory purposes, and a small business without formal policy is not an exception. If you do enter figures on personnel distribution without underlying policy, split those two in the supply chain file: the distribution is a hard measurement, the policy is a yes/no with possibly a reference to a document. For the approach to this specific question in a questionnaire, there is a separate elaboration of how you complete the diversity question about your workforce.

What this is based on: VSME labour forces module

The basic module of EFRAG VSME addresses labour forces as a separate section, with quantitative indicators on the composition of personnel. Directive 2022/2464 (CSRD) is the underlying directive that created the reporting standards for sustainability information, of which VSME is the voluntary, simplified variant for non-listed SMEs. A separate policy document on diversity and inclusion is not a mandatory element in the basic module itself; that distinction between figures and policy is the reason why this label is still to be determined until you know which of the two your client is asking for.