Summary
The Guidelines have set a transition period of three years after its official promulgation, meaning companies can apply them on a voluntary basis during this period. Companies that are ready can implement the Guidelines immediately. Following the transition period, companies shall apply the Guidelines under the “comply or explain” approach, meaning that if companies cannot comply with the Guidelines, they must explain any non-compliance and the respective reasoning in their annual reports. The provisions of these Guidelines shall apply to all listed companies on a “comply or explain” basis, except when an element of the Guidelines is already enshrined in law. In the latter case, the law/regulation must be fully applied and complied with.