customer asks if we have a documented sustainability policy, and we don't have it in writing

Without a document, the answer is usually no

A written sustainability policy is a separate document: a text that states what the enterprise wants to achieve in the field of sustainability and how. Practice that is not written down does not count here as "policy" — even if you have been consciously handling energy or waste for years. Without that document, the honest answer to this question is usually no, and you can simply indicate that.

More important than the answer to this one question is what comes next. The VSME basic module of EFRAG often asks not only "yes/no" for this type of question, but also a brief explanation: which topics the policy covers, who adopted it, and whether it is public. If you have no policy, then "no, not yet established" is a valid answer — stronger than a hastily drawn up document of half a page with no substance. Customers often compare this type of answer with other parts of the list, such as who sits on the board and how it is composed: an empty policy field next to a clear board answer is less noticeable than a list that gives evasive answers everywhere.

Where this comes from: the VSME base module

The question about a written sustainability policy comes directly from the basic module of EFRAG's VSME standard, intended for non-listed SMEs that need or want to provide this kind of information to customers or financiers. This standard is voluntary — there is no legal obligation under VSME itself to have the policy — but large customers use it as a fixed format because CSRD (Directive 2022/2464) requires them to collect this type of data about their own supply chain. Similar "do you have an established policy" questions appear in related topics, such as the policy against bribery and corruption: the answer is often no as long as there is no separate document, which in itself is not a problem for filling in the list.