You now understand VSME. You’re ready to start. And then you hit this wall:

“Where do I get energy consumption data?” “Do I just ask HR for headcount?” “I get what Scope 1 means in theory — but how do I actually calculate it?”

This post walks through, item by item, which department owns each VSME data point and how to ask for cooperation in a way that actually works.

The real reason VSME response is hard

The VSME items aren’t conceptually difficult. B3 asks for energy consumption. B8 asks for headcount. The questions themselves are simple.

The hard part is one specific thing:

The data is scattered across multiple departments, and the people holding it have never heard of VSME.

Energy data sits with General Affairs, who manages the electricity bills. Workforce data sits with HR. Incident data sits with EHS, or in the regulatory filings to the Ministry of Employment. Trying to chase all of this down alone takes weeks.

The fix is straightforward: figure out exactly who to ask for what, and ask cleanly the first time.

Full mapping: VSME items by source department

Environmental data

VSME itemRequired dataOwnerSource
B3 Energy / GHGAnnual electricity (kWh)General Affairs / FacilitiesElectricity bill (KEPCO)
B3 Energy / GHGAnnual natural gas (Nm³)General Affairs / FacilitiesGas bill
B3 Energy / GHGAnnual diesel / gasoline (L)General Affairs / fleetRefueling records, corporate card
B4 PollutionPermit-limit exceedancesEHS / QualityMinistry of Environment filings, ISO 14001
B5 BiodiversityProximity to sensitive areasGeneral AffairsSite address review
B6 WaterAnnual water (m³)General Affairs / FacilitiesWater bill
B7 WasteAnnual waste tonnageEHS / ProductionWaste handler receipts, manifest log

Workforce / social data

VSME itemRequired dataOwnerSource
B8 WorkforceTotal headcount (FTE / non-FTE)HRHR system
B8 WorkforceGender ratioHRHR system
B8 WorkforceNationality (domestic / foreign)HRHR system
B9 H&SAnnual incident countEHSMinistry of Employment incident filings
B9 H&SFatalitiesEHSMinistry of Employment filings
B10 Pay / trainingMinimum wage complianceHRPayroll baseline
B10 Pay / trainingAnnual training hours per employeeHR / L&DTraining records

Governance data

VSME itemRequired dataOwnerSource
B1 Basic infoLegal form, NACE code, turnover, headcountCorporateBusiness registration, financials
B2 PoliciesExistence of E / S / ethics policiesCorporate / LegalInternal policy documents
B11 Corruption / briberyConvictions in the last 3 yearsCorporate / LegalDisclosures, internal review

How to ask each department for cooperation

Department owners don’t know what VSME is. Trying to explain it usually slows you down. The faster path is to specify what data, in what format, by when — explicitly.

Template — General Affairs / Facilities

Subject: ESG data request for European customer submission

Hi [team],

A European customer has requested ESG-related documentation. Could you share the
following for [reference year], by [deadline]?

Data needed:
1. Annual electricity (kWh) — sum of monthly KEPCO bills
2. Annual natural gas (Nm³) — sum of monthly gas bills
3. Annual water (m³) — sum of monthly water bills
4. Annual diesel / gasoline (L) — corporate-card refueling records

Original bills or an Excel summary — either is fine.

Thanks,
[Your name]

Template — HR

Subject: ESG data request for European customer submission — workforce

Hi [team],

For an ESG submission to a European customer, I need the following workforce
data, as of [Dec 31] cutoff, by [deadline]:

Data needed:
1. Total headcount (FTE / non-FTE breakdown)
2. Gender breakdown (male / female)
3. Nationality (domestic / foreign)
4. Minimum wage compliance (yes / no)
5. Average annual training hours per employee
6. % of employees covered by collective bargaining

Thanks,
[Your name]

Template — EHS

Subject: ESG data request — H&S and waste

Hi [team],

For [reference year] annual basis, I need the following by [deadline]:

Data needed:
1. Annual workplace incident count (including minor injuries)
2. Annual fatalities
3. Annual total waste tonnage
   - Standard / hazardous breakdown
   - Recycling / incineration / landfill split
4. Permit-limit pollutant exceedances (if any, with cause)

Reference: incident filings to the Ministry of Employment, plus
waste handler receipts.

Thanks,
[Your name]

The hardest item: Scope 1·2 in practice

B3 (Energy / GHG) feels intimidating because of the unfamiliar term “Scope 1.” The principle is actually simple.

Scope 1 vs Scope 2 in plain language

Scope 1 (direct emissions): GHG from fuels burned at facilities you own or operate.

Examples:
- Boilers burning natural gas, diesel, or LPG
- Forklifts and company vehicles burning diesel / gasoline
- On-site backup generators

Scope 2 (indirect emissions): GHG from generating the electricity you purchased.

Examples:
- Factory and office electricity use
(Electricity itself doesn't emit, but generating it does — that's Scope 2)

The actual calculation (utility bills are sufficient)

Scope 2 — electricity:

Scope 2 (tCO₂eq) = annual electricity (MWh) × emission factor

Korean grid factor (2023): 0.4154 tCO₂/MWh
(MOTIE official, updated annually)

Example: 500,000 kWh = 500 MWh
→ 500 × 0.4154 = 207.7 tCO₂eq

Scope 1 — primary fuels:

Natural gas: usage (Nm³) × 0.002176 (tCO₂eq/Nm³)
Diesel:     usage (L)   × 0.002619 (tCO₂eq/L)
Gasoline:   usage (L)   × 0.002280 (tCO₂eq/L)
LPG:        usage (kg)  × 0.002996 (tCO₂eq/kg)

(Korean Ministry of Environment GHG emission factors)

Worked example:

[Hypothetical Korean SME manufacturer A — 80 employees]

Electricity:  480,000 kWh/yr → 480 MWh
Natural gas:   24,000 Nm³/yr
Diesel (fleet): 3,600 L/yr

Scope 2 = 480 × 0.4154 = 199.4 tCO₂eq
Scope 1 = 24,000 × 0.002176 + 3,600 × 0.002619
        = 52.2 + 9.4 = 61.6 tCO₂eq

Total emissions = 261.0 tCO₂eq/year

With electricity bills, gas bills, and refueling records in hand, this calculation takes 30 minutes. EFRAG’s free Excel template auto-applies the formulas.

Four common mistakes on first response

Mistake 1: Trying to do everything alone

VSME is genuinely not a one-person job. Energy data sits with General Affairs; workforce data with HR; waste data with EHS. Send cooperation requests to each department from day one.

Mistake 2: Estimating missing data and submitting it as actuals

If you don’t have a number, enter “Not measured” honestly. Submitting an estimate as if it were a measured value creates a credibility problem when the buyer asks for verification later.

Mistake 3: Mixing reference periods

Submitting B3 energy data on FY2024 basis and B8 workforce data on January 2025 basis creates inconsistency. Lock in one reporting year (or cutoff date) for the entire report and document it in B1.

Mistake 4: Not confirming the requested module scope

Preparing the Comprehensive Module (C1–C9) when the buyer only asked for the Basic Module — or vice versa. Confirm before you submit: “Basic Module only, or also Comprehensive?”

How to make the next response easier

If this is your first VSME response, do these two things now to make next time half the work.

(1) Build a department contact list

Energy data    → General Affairs   [name] [contact]
Workforce data → HR                [name] [contact]
Waste data     → EHS               [name] [contact]
Basic info     → Corporate         [name] [contact]

This single list cuts your next response time roughly in half.

(2) Save monthly utility bills in a shared folder

Starting today, archive electricity, gas, and water bills monthly in a shared folder. Next year’s VSME update becomes “sum the 12 months” — and B3 / B6 are done.

Coming next

The next post tackles the question: “Once we’ve prepared this data once, can we reuse it for the next request?” We cover how to build a reuse-ready data structure and how to keep the institutional memory intact when the responsible person changes.

→ Episode 5: Can the ESG Report We Just Built Be Reused for the Next Request?