gssbsecretariat@globalreporting.org

Item 02 – GRI Topic Standard Projectfor Labor – Employment – Exposure
draft
For GSSB approval
Date

26 April 2024

Meeting

16 May 2024

Project

GRI Topic Standard Project for Labor

Description

This document sets out the exposure draft of the GRI Employment Standard,
including the explanatory memorandum summarizing the objectives of the project
and the significant proposals contained within the draft. These are submitted for
GSSB approval for public exposure.
If approved, public exposure is proposed to commence in early June and run untillate September 2024.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2024

GRI EMPL: Employment

Page 2 of 34

Content
Introduction ........................................................................................................................................ 4
1. Topic management disclosures .............................................................................................. 8
Disclosure EMPL 1 Employment arrangements ................................................................................. 8
Disclosure EMPL 2 Apprenticeship and internship ........................................................................... 10
Disclosure EMPL 3 Recruitment policies .......................................................................................... 12
Disclosure EMPL 4 Performance management systems .................................................................. 14
Disclosure EMPL 5 Personal data protection and privacy policies ................................................... 16
Disclosure EMPL 6 Termination policies ........................................................................................... 18
2. Topic disclosures ....................................................................................................................... 19
Disclosure EMPL 7 New hires and turnover ...................................................................................... 19
Disclosure EMPL 8 Incidents related to recruitment ......................................................................... 26
Disclosure EMPL 9 Performance reviews ......................................................................................... 27
Disclosure EMPL 10 Incidents related to personal data protection and privacy ............................... 29
Glossary ............................................................................................................................................. 30
Bibliography ...................................................................................................................................... 34

Page 3 of 34

1

Introduction

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3

GRI EMPL: Employment 202X contains disclosures for organizations to report information about theiremployment-related impacts, and how they manage these impacts.

4

The Standard is structured as follows:

56•

Section 1 contains six disclosures, which provide information about how the organization
manages its employment-related impacts.

78•Section 2 contains four disclosures, which provide information about the organization’s
employment-related impacts.

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11

•

The Glossary contains defined terms with a specific meaning when used in the GRI
Standards. The terms are underlined in the text of the GRI Standards and linked to thedefinitions.

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13

•

The Bibliography lists authoritative intergovernmental instruments and additional referencesused in developing this Standard.

The rest of the Introduction section provides a background on the topic, an overview of the system of
GRI Standards and further information on using this Standard.
14

Background on the topic
This Standard addresses the topic of employment.

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An employment relationship is a legal link between a worker and an organization that confers rights
and obligations to both parties. This relationship is usually the means for determining whether
employment, labor, or commercial law is applicable. These concepts are covered in key International
Labour Organization (ILO) instruments. See the Bibliography.

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The most traditional relationship between an organization and its workers is direct and continuous andin the form of permanent full-time employment. However, there are several forms of employment.
Organizations can employ workers directly, such as part-time, and non-guaranteed hours
employment, or indirectly, such as in temporary agency work.

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The rise of diverse forms of employment can be attributed to social and demographic changes,
macroeconomic fluctuations, and technological advancements. These changes have created
opportunities for previously excluded people from the labor market. For instance, part-time work canhelp individuals with family responsibilities enter the job market. Temporary work may be preferred byworkers who cannot commit to work for an indefinite duration. These diverse forms of employment
also pose risks for the worker, including job and income insecurity due to short-term contracts andirregular schedules. Fair recruitment refers to recruitment done according to law and in line withinternational labor standards that protect workers from exploitative situations.

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By implementing an effective performance management system, workers can improve their skills andemployability and receive training and development opportunities to advance their careers.

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Workers have a right to privacy and data protection during working hours, even at the organization's
disposal. Organizations are expected to be transparent about data collection and monitoring andobtain workers' informed consent for collecting personal data throughout an employment relationship.

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The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization. Control of work implies that the organization directs thework performed or controls the means or methods for performing the work. See Control of Work
Standard Interpretation to GRI 2 for more information.

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40

System of GRI Standards

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This Standard is part of the GRI Sustainability Reporting Standards (GRI Standards). The GRI
Standards enable an organization to report information about its most significant impacts on theeconomy, environment, and people, including impacts on their human rights, and how it manages
these impacts.

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The GRI Standards are structured as a system of interrelated standards that are organized into threeseries: GRI Universal Standards, GRI Sector Standards, and GRI Topic Standards (see Figure 1 inthis Standard).

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Universal Standards: GRI 1, GRI 2 and GRI 3

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GRI 1: Foundation 2021 specifies the requirements that the organization must comply with to report inaccordance with the GRI Standards. The organization begins using the GRI Standards by consulting
GRI 1.

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GRI 2: General Disclosures 2021 contains disclosures that the organization uses to provide
information about its reporting practices and other organizational details, such as its activities,
governance, and policies.

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GRI 3: Material Topics 2021 provides guidance on how to determine material topics. It also contains
disclosures that the organization uses to report information about its process of determining material
topics, its list of material topics, and how it manages each topic.

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Sector Standards

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The Sector Standards provide information for organizations about their likely material topics. The
organization uses the Sector Standards that apply to its sectors when determining its material topics
and when determining what to report for each material topic.

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Topic Standards

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The Topic Standards contain disclosures that the organization uses to report information about its
impacts in relation to particular topics. The organization uses the Topic Standards according to the listof material topics it has determined using GRI 3.

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66

Figure 1. GRI Standards: Universal, Sector and Topic Standards

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Using this Standard

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This Standard can be used by any organization – regardless of size, type, sector, geographic location,or reporting experience – to report information about its employment-related impacts. In addition tothis Standard, disclosures that relate to this topic can be found in:• GRI TRED: Training and Education 202X
• GRI PARE: Working Parents and Caregivers 202X
• GRI REWO: Remuneration and Working Time 202X
• GRI SICH: Significant Changes for Workers 202X
• GRI 403: Occupational Health and Safety 2018
• Control of Work Standard Interpretation to GRI 2

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An organization reporting in accordance with the GRI Standards is required to report the following
disclosures if it has determined employment to be a material topic:

80•

Disclosure 3-3 in GRI 3: Material Topics 2021.

81
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•

Any disclosures from this Topic Standard that are relevant to the organization’s employmentrelated impacts (Disclosure EMPL-1 through Disclosure EMPL-9).

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See Requirements 4 and 5 in GRI 1: Foundation 2021.

84

Reasons for omission are permitted for these disclosures.

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If the organization cannot comply with a disclosure or with a requirement in a disclosure (e.g.,
because the required information is confidential or subject to legal prohibitions), the organization isrequired to specify the disclosure or the requirement it cannot comply with and provide a reason foromission together with an explanation in the GRI content index. See Requirement 6 in GRI 1 for more
information on reasons for omission.

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90
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If the organization cannot report the required information about an item specified in a disclosure
because the item (e.g., committee, policy, practice, process) does not exist, it can comply with therequirement by reporting this to be the case. The organization can explain the reasons for not having
this item or describe any plans to develop it. The disclosure does not require the organization to
implement the item (e.g., developing a policy), but to report that the item does not exist.

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If the organization intends to publish a standalone sustainability report, it does not need to repeat
information that it has already reported publicly elsewhere, such as on web pages or in its annual
report. In such a case, the organization can report a required disclosure by providing a reference in
the GRI content index as to where this information can be found (e.g., by providing a link to the web
page or citing the page in the annual report where the information has been published).

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Requirements, guidance and defined terms

101

The following apply throughout this Standard:

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Requirements are presented in bold font and indicated by the word 'shall'. An organization mustcomply with requirements to report in accordance with the GRI Standards.

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Requirements may be accompanied by guidance.

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Guidance includes background information, explanations, and examples to help the organization
better understand the requirements. The organization is not required to comply with guidance.

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The Standards may also include recommendations. These are cases where a particular course ofaction is encouraged but not required.

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The word ‘should’ indicates a recommendation, and the word ‘can’ indicates a possibility or option.

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Defined terms are underlined in the text of the GRI Standards and linked to their definitions in the
Glossary. The organization is required to apply the definitions in the Glossary.

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112

1. Topic management disclosures

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An organization reporting in accordance with the GRI Standards is required to report how it manages
each of its material topics.

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An organization that has determined employment to be a material topic is required to report how it
manages the topic using Disclosure 3-3 in GRI 3: Material Topics 2021. The organization is also
required to report any disclosures from this section (Disclosure EMPL 1 through Disclosure EMPL 6)that are relevant to its employment-related impacts.

119This section is therefore designed to supplement – and not replace – Disclosure 3-3 in GRI 3.

120

Disclosure EMPL 1 Employment arrangements

121

REQUIREMENTS

122

The organization shall:

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a. describe how it protects employees and workers who are not employees against
disguised employment;

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b. describe the actions it has taken to transition temporary employees to permanent
employees;

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c. describe how third parties providing workers who are not employees are monitored andadhere to international labor standards, including fundamental principles and rights at
work.

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GUIDANCE

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This disclosure aims to understand how the organization avoids disguised forms of employment,
promotes employment security by offering opportunities to transition to permanent employment, andmonitors that temporary work agencies respect fundamental principles and rights at work. According
to the International Labour Organization (ILO), the five fundamental principles and rights at work thatorganizations need to uphold are:• freedom of association and the effective recognition of the right to collective bargaining;• the elimination of all forms of forced or compulsory labor;• the effective abolition of child labor;• the elimination of discrimination with respect to employment and occupation;• a safe and healthy working environment.

141

See reference [7] in the Bibliography.

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The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation for more information.

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Guidance to EMPL 1-a

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According to the ILO’s Employment Relationship Recommendation, 2006 (No. 198) [1], disguised
employment occurs when organizations treat workers in a manner that hides their actual legal statusas employees. This can lead to contractual arrangements depriving workers of their due protection. In
disguised employment, workers can be given a commercial contract instead of an employment
contract while having no independence to work with other organizations.

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Workers in disguised employment are unlikely to be covered by labor legislation. As a result, they do
not have access to social protection, including paid sick leave, earn lower remuneration, work longer
hours, and are more exposed to occupational health and safety risks compared to employees.
Workers in disguised employment are unlikely to exercise their fundamental rights at work, such as
freedom of association and collective bargaining, because many jurisdictions restrict these rights
to employees. See Disclosure REWO 5 Remuneration and working time for more information onsocial protection.

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When reporting on how they protect against disguised employment, organizations can describe how
they determine an employment relationship and the distinction between employed and self-employedworkers. They can also report their actions to prevent disguised employment, such as training humanresource employees. In addition, organizations can avoid unnecessary exclusivity agreements.

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The organization can describe how it provides collective bargaining structures or access to grievancemechanisms and other remediation processes for workers to ensure that where a dispute over an
employment relationship occurs, it can be appropriately resolved.

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When reporting under Disclosure 2-25 in GRI 2: General Disclosures 2021, the organization canreport workers who are not employees to access grievance mechanisms and other remediation
processes to address grievances related to disguised employment.

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Guidance to EMPL 1-b

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Temporary employment allows organizations to meet changes in labor demands, such as seasonal
fluctuations, or evaluate new employees before providing a permanent contract. It also allows
employees to balance work with other activities, such as full-time education.

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Involuntary temporary employment occurs when employees are engaged in temporary roles without it
being their explicit choice, such as when they are unable to secure permanent employment. Often,
temporary employment arrangements can be inferior to permanent employment, such as providing
lower remuneration. In addition, due to the nature of temporary employment, there are higher chancesof unemployment and inadequate social protection. Actions to increase workers’ transition from
temporary to permanent employment can include improved planning to understand an organization’s
staffing needs and limit the duration and number of renewals of temporary contracts.

180

Guidance to EMPL 1-c

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Workers who are not employees can have contractual relationships involving multiple parties. For
example, this can include workers, the organization, and a third-party intermediary, such as atemporary work agency or sub-contractor. There is no direct employment relationship between thetemporary agency worker and the organization. For example, temporary workers are employed by an
employment agency and hired out or assigned to work at for the reporting organization. Other
contractual arrangements involving multiple parties include outsourcing, subcontracting, andfranchising.

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For workers, contractual relationships involving multiple parties can lack rights such as freedom of
association and collective bargaining and involve forced or compulsory labor, discrimination, or lower
remuneration. Therefore, the organization needs to monitor contractual relationships involving
multiple parties. Organizations can report how they monitor these third parties through, for example,
rigorous screening of the agencies providing workers, providing capacity building to agencies on
fundamental principles and rights at work, or auditing agencies for social compliance.

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Following the ILO's, Private Employment Agencies Convention, 1997 (No. 181), private employment
agencies must protect and respect workers' privacy in accordance with national law when processing
their personal data. For more information, see Disclosure EMPL 5 in this Standard.

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In Disclosure 2-8 in GRI 2: General Disclosures 2021 the organization should report whether it engages

202

See references [3] and [10] in the Bibliography.

with workers who are not employees or indirectly through a third party, and in the latter case, who this third partyis (e.g., employment agency, contractor). According to GRI 403: Occupational Health and Safety 2018,the organization is expected to be responsible for the occupational health and safety of all workers
who are not employees.

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203

Disclosure EMPL 2 Apprenticeship and internship

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REQUIREMENTS

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The organization shall:

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a. describe its policy on apprenticeship and internship including:

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i.

whether remuneration is paid to all apprentices and interns and, if not, provide a listof locations of operation where remuneration is not paid and explain why;209

ii. minimum and maximum duration of an apprenticeship and internship in weeks;210iii. maximum hours of work in a week;

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iv. whether all apprentices and interns are entitled to paid annual leave, sick leave,maternity or paternity leave, and parental leave, and, if not, provide a list of locationsof operations where the types of leave are not provided and explain why.

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GUIDANCE

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This disclosure provides the conditions related to organizations’ apprenticeships and internships.
Apprenticeships and internships are crucial to a worker's skills development, lifelong learning, andemployability. However, they can also expose workers to exploitative conditions, such as long working
hours, insufficient social protections, and unsafe workplaces.

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According to the ILO's Quality Apprenticeships Recommendation, 2023 (No. 208) [2], anapprenticeship is a form of education and training governed by an agreement that enables anapprentice to acquire the skills and competencies relevant to a specific occupation. The
apprenticeship should be fairly remunerated or otherwise financially compensated through structured
training consisting of both on- and off-the-job learning, or lead to a recognized qualification.

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While there is no internationally recognized definition for an internship, it can be understood as workwithin an organization to acquire experience, skills, and contacts to secure future employment orother work opportunities However, internships do not provide all the skills needed for a particularoccupation in a structured manner [19].

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Organizations can also report their policy for other forms of vocational training they provide anddescribe how it offers employment upon completion of training. See GRI TRED: Training and
Education 202X for more information on training and education in the workplace.

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The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

235

Guidance to EMPL 2-a

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Organizations need to report the information in EMPL 2-a-i to iv for apprentices and interns
separately. The organization can include information on its apprenticeship and internship programs,
such as:

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•
•
•

the learning objectives or curriculum of the training and education activities of apprentices orinterns;
number of hours undertaken in training and education activities by the apprentices andinterns. Program outcomes, such as the qualification acquired upon successful completion or
credits for a university degree program;affiliation with training and education institutions.

Recruitment and selection process for apprenticeships and internships. This can include any
educational qualifications, attainments, or prior learning required for admission. Recruitment may bedirect or indirect. See Disclosures TRED 2 and 3 in GRI TRED: Training and education 202X for more
information on content and type of training, and number of hours of training and education activities
undertaken.

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250

Guidance to EMPL 2-a-i

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Remuneration should be for regular hours of work. See Disclosure REWO 1 in GRI REWO:
Remuneration and Working Time 202X for regular hours of work.

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The organization should describe any related fees and costs of apprenticeships and internships andwho covers them. This could include course fees, materials, and fees for an apprenticeship orinternship. See EMPL 3 in this Standard for recruitment costs and GRI REWO for more information
about deductions from remuneration)

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Guidance to EMPL 2-a-ii

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The organization should state the minimum and maximum duration of the apprenticeships andinternships needed to gain qualifications, competencies, and work experience. The organization
should state if the duration is reduced based on prior learning or progress made during theapprenticeship or internship.

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Guidance to EMPL 2-a-iii

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The hours of work should not include overtime. See Disclosure REWO 2 in GRI REWO Remuneration
and working time 202X.

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Guidance to EMPL 2-a-iv

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The organization should report for each type of leave not provided, the locations of operation where
the leave is not offered, and the reasons why. Additionally, the organization can report the number ofdays off that apprentices and interns receive for each type of leave.

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See Disclosures REWO 2 and 5 in GRI REWO: Remuneration and Working Time 202X for more
information on annual, sick, and maternity or paternity leave. Further guidance on parental leave canalso be found in Disclosure PARE 1 in GRI PARE: Working Parents and Caregivers 202X.

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Disclosure EMPL 3 Recruitment policies

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REQUIREMENTS

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The organization shall:

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a. describe how it monitors direct and indirect recruitment for job seekers, employees, andworkers who are not employees, including:

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i.

whether the recruitment fees or related costs are not charged to, or otherwise borneby workers;

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ii. whether the worker’s informed consent to the terms and conditions of work is
obtained without deception or coercion;

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iii. whether international labor standards, including fundamental principles and rights atwork, are adhered to;

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iv. whether job seekers and workers have access to effective grievance mechanisms andother remediation processes in cases of alleged abuse of rights during recruitment.

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GUIDANCE

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Recruitment consists of advertising, information dissemination, selection, transport, and placement
into employment. Direct recruitment occurs when the organization administers all aspects ofrecruitment, whereas indirect recruitment occurs when the organization works with entities such as
public employment services or private employment agencies.

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The ILO’s General Principles and Operational Guidelines for Fair Recruitment, 2019 [8], explains theconcept of fair recruitment and how it should work in practice. Fair recruitment adheres to legal
regulations and international labor standards that protect workers from exploitative conditions.

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The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See Control of Work Standard Interpretation to GRI 2 for more information.

297

Guidance to EMPL 3-a-i

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Recruitment fees or related costs refer to any fees or costs incurred in the recruitment process forworkers to secure employment or placement. Recruitment fees or related costs also include payments
made in the form of gifts to an employee of the organization or labor recruiters for the purpose of
securing employment. According to the ILO’s General Principles and Operational Guidelines for Fair
Recruitment, 2019, prospective employers, public or private, or their intermediaries, bear the cost of
recruitment and not workers. This is also reiterated in the ILO’s Private Employment Agencies
Convention, 1997 (No. 181) [3], which states that workers and job seekers are not charged directly or
indirectly, in whole or in part, any fees or related costs for their recruitment.

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When monitoring recruitment costs, the organization can check for recruitment fees or related
expenses, such as payments made in the form of gifts to an employee of the organization or labor
recruiters to secure employment. In addition, job advertisements, offer letters, contracts, or any othertype of communication with job seekers or workers should indicate that recruitment fees and related
costs are not charged to them.

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Guidance to EMPL 3-a-ii

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Terms and conditions of work can include:• name and address of the employer and the worker;• address of the workplace(s);• starting date and, where the contract is for a specified period, its duration;• type of work to be performed;• remuneration, method of calculating the remuneration, and frequency of payments;• normal hours of work;• paid annual leave and daily and weekly rest periods;• personal data protection and data privacy;

Page 12 of 34

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•
•
•
•

provision of food and accommodation;
period of probation or trial period;
terms of repatriation;
terms and conditions relating to the termination of employment, including any notice period byeither the worker or the employer.

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In its recruitment policy, the organization can state that terms and conditions of work are specified in
written contracts given to workers before the start date of the job and in a language they understand.

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Furthermore, the organization can monitor any change in the recruitment policy making sure theorganization does not change the terms and conditions of work that the worker has agreed to andreplace them with new terms and conditions upon their arrival. The organization can also explain
whether measures are in place to prevent contract substitution.

332

Guidance to EMPL 3-a-iii

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International labor standards are legal instruments drawn up by the ILO constituents and set out basic
principles and rights at work. The organization should describe how it oversees any recruitment
policies and processes in alignment with labor standards. For example, the organization can conduct
internal audits to evaluate recruitment practices or external recruiters. The organization can also
indicate other mechanisms to review and analyze ongoing processes to ensure recruitment meetslabor standards. In addition, it can implement surveys to understand the job seekers’ and workers’
experience during the recruitment process.

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See reference ILO’s Declaration on Fundamental Principles and Rights at Work, 2022 [7], in the
Bibliography.

342

Guidance to EMPL 3-a-iv

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The organization should describe the type of grievance mechanism available to job seekers,
employees, and workers who are not employees. In addition, it should describe how grievances arecollected, processed, and stored in determined systems following data privacy policies.

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When the organization uses indirect recruitment, it should describe how it monitors external recruiters,
making grievance mechanisms available to job seekers. When reporting grievance mechanisms andother remediation processes under Disclosure 2-25 in GRI 2: General Disclosures 2021, theorganization can report how these mechanisms and processes are available to support the monitoringof recruitment practices.

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Disclosure EMPL 4 Performance management systems

352

REQUIREMENTS

353

The organization shall:

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a. describe its performance management system for its employees and for workers who are
not employees, including how it:

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i. ensures it is objective and impartial;
ii. respects the fundamental principles and rights at work;iii. contains an appeals process.

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GUIDANCE

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A performance management system is a structured approach to measuring worker performance. It
communicates goals, objectives, responsibilities, constructive feedback, and worker development
plans. It assesses workers' competency and skill level by how effectively they fulfill their roles andcomplete tasks and training.

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An essential part of a performance management system is a performance review. This is usually ameeting between the worker and the organization's management to discuss the evaluation of theworker's performance and the type of work they are completing. The review can explore possible
training, future objectives, and career development opportunities. Ensuring procedural objectivity andimpartiality is important as it gives employees confidence in the performance management system.

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The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

373

Guidance to EMPL 4-a

374

The organization can describe the following aspects of the performance management system:

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•
•
•
•
•
•

Performance outcomes: how a worker's performance outcomes, competencies, and training
needs are set. This could be connected to organizational goals and areas of improvement for
the worker.
Performance evaluation: how worker performance is evaluated.
Rating mechanism: the system it uses to measure the performance.
Rewards and recognition: whether the organization’s culture recognizes good performanceand, if so, how the system supports this with rewards and recognition. This can include merit
increments, promotions, additional leave, or training programs.
Unsatisfactory performance: how this is identified and discussed with the worker, and theperformance improvement plans devised, such as additional training and counselling.
Career development: how the performance management system is linked to workers' careerdevelopment.

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The organization should report the frequency of the performance review, for example, an annual
performance review. It should also explain how it conducts a performance review for workers
appointed or transferred to the position in the middle of the review period. The organization should
describe how the performance management system is accessible to all employees and workers who
are not employees. For example, the organization can report how it communicates the information in
a format accessible to workers with disabilities.

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396

The organization should describe how data is collected for employees and workers who are not
employees as part of its performance management system, such as performance tests andmonitoring data. How data related to the worker's performance and evaluation are processed andmonitored is reported under Disclosure EMPL 5 in this Standard.

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The organization can report if it received involvement from worker representatives regarding theperformance management system.

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403
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The organization should describe how it addresses unsatisfactory performance in its performance
management system. Unsatisfactory performance is when a worker does not perform the expected
duties or does not meet the required quality criteria for the role, which could lead to termination of
employment (see Disclosure EMPL 5 in this Standard). According to the ILO's Termination of
Employment Recommendation, 1982 (No. 166) [5], organizations are expected not to terminate aworker for unsatisfactory performance unless they have given the worker appropriate instructions on
how to improve, a written warning, and a reasonable period to improve performance.

406

Guidance to EMPL 4-a-i

407
408
409
410
411
412

An objective performance management system is based on information, data, and observableoutcomes on the worker's performance. An impartial performance management system treats all
employees fairly and avoids any subjective influences, such as the opinions of supervisors and othercolleagues. Measures to ensure objectivity include training managers to administer performance
reviews impartially, ensuring workers are well-informed of the process and what is expected, andensuring that objectives are specific, measurable, achievable, relevant, and time-bound.

413

Guidance to EMPL 4-a-ii

414
415
416
417

Organizations should describe how they ensure a performance management system and any relevant
performance indicators do not lead to actual or potential impacts on fundamental principles and rights
at work. For example, a worker's daily targets must be feasible to complete within the maximum daily
working time limits and without risk to health and safety.

418
419
420
421

The organization should describe how it ensures that the performance management system andreviews are conducted without discrimination. This could include regularly reviewing processes toevaluate potential biases and adjusting performance targets for the workers' circumstances (e.g.,pregnant workers).

422

Guidance to EMPL 4-a-iii

423
424
425
426
427

An appeals process allows workers to file a grievance about the performance management system's
process or outcome. It can include an opportunity for the worker to respond to the assessment,
access a grievance mechanism, meet a worker representative, and appeal the result. The
organization can report whether workers are informed about the appeals process, such as the days tosubmit an appeal or grievance.

428
429
430
431

When reporting on grievance mechanisms and other remediation processes under Disclosure 2-25
in GRI 2: General Disclosures 2021, the organization can report how these mechanisms andprocesses are available to workers who are not employees to address grievances related to disguised
employment.

Page 15 of 34

433

Disclosure EMPL 5 Personal data protection andprivacy policies

434

REQUIREMENTS

435

The organization shall:

436
437

a. describe its policies on personal data protection and privacy for employees and workers
who are not employees, including:

432

438
439
440

i. the type of personal data collected;
ii. the processing of personal data;iii. the type and purpose of monitoring activities;

441
442

b. describe the measures to obtain employees and workers who are not employees’ informed
and explicit consent related to data processing and monitoring activities;

443
444

c. describe how worker representatives are involved in developing and implementing
personal data protection and privacy policies.

445

GUIDANCE

446
447

This disclosure covers how organizations process and monitor information on workers' activities,
communications, and private lives within a working environment.

448
449
450
451
452

Workers have a right to privacy even when they are at the organization's disposal during working
hours. The right to privacy refers to the right to a private life and control of one’s information.
Breaching workers' privacy includes unnecessary intrusions into workstations, lockers, bodysearches, and social and personal intrusions, such as unnecessary inquiries into personal lives orreligious beliefs.

453
454
455
456

Data protection refers to safeguarding information related to an identified or identifiable person. This
includes data such as name, address, date of birth, and phone number. The concept of dataprotection comes from the right to privacy. Data privacy refers to preventing the sale or sharing of
personal data without the individual’s informed consent.

457

See references [6] and [19] in the Bibliography.

458
459
460
461

The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

462

Guidance to EMPL 5-a

463
464
465

The organization is required to separately report the information in EMPL 5-a-i to iv for employees
and workers who are not employees. The organization should also report what personal data iscollected for other workers, such as workers who have left the organization and job seekers.

466

Guidance to EMPL 5-a-i

467
468
469
470

Personal data is any information related to an identified or identifiable person. Organizations collectworkers' data for many purposes, such as compliance with regulations, recruitment, training, andpromotion, as well as personal safety, quality control, and the protection of the organization's
property. Examples of personal data include those related to:

471
472
473
474
475
476
477

•
•
•
•
•

the position of the workers in the organization, such as type of employment contract, salary,and benefits;
performance assessments and personality traits;
sexual orientation, ethnicity, demographic data, medical history, and participation in social
media networks;
current or former trade union membership, and political, religious, and other beliefs;
biometrics, such as fingerprints or facial recognition.

Page 16 of 34

478

Guidance to EMPL 5-a-ii

479
480
481
482
483
484
485
486

Processing of personal data includes the collection, storage, use, or communication of personal data.
This includes manual, digital, and automatic processing of workers' data, including traditional filekeeping and automated digital personnel information systems. For example, the organization canensure data protection by implementing login controls to access digitally stored information, keeping
files containing workers’ information separate, and setting firewalls. Collecting the minimum
necessary data about the workers, storing data only for a limited period, and setting up systems tomonitor the flow of personal data are further examples of how the organization can ensure data
privacy.

487
488

The organization should report the purposes of the data collection and how long the data is kept, suchas after the employment application or when a worker leaves the organization.

489

Guidance to EMPL 5-a-iii

490
491
492
493
494
495

Monitoring includes using devices such as computers, cameras, video equipment, sound devices,
telephones, and other communication equipment to establish the identity and location of workers.
Monitoring can be on- or off-site, such as in the organization's premises and sites or the worker's
home. It can also include recording telephone conversations when a worker is talking to customers,
video surveillance when a worker manufactures high-value goods and monitoring the location of aworker delivering goods.

496
497
498
499
500

The organization may have legitimate reasons for monitoring workers, such as recording time worked
to ensure overtime pay is accurately calculated and recording entries and exits within secure areas toprotect assets. However, inadequately managed monitoring, lacking adherence to legal guidelines,
and failing to inform workers about such activities can invade a worker's privacy, diminish morale, andundermine trust between the worker and the organization.

501
502
503

Monitoring can also evaluate a worker's performance, such as their digital activity, emailcommunications, or speed and success rate in resolving assigned cases. See Disclosure EMPL 4 inthis Standard for more information.

504

Guidance to EMPL 5-a-iv

505
506
507
508
509

According to the ILO's Code of Practice on Protection of worker's personal data, 1997 [19], theorganization is expected to obtain workers’ informed and explicit consent related to data processing
and monitoring activities. This ensures workers have sufficient information to consent to the gatheringor releasing of their data. Explicit consent would typically mean written consent. If there is no writtenconsent, this must be justified. In such cases, information and consent may have to be given verbally.

510

Guidance to EMPL 5-b

511
512
513
514
515
516
517
518
519

Organizations can report any negotiations with worker representatives concerning the induction or
modification of workers' data, monitoring of workers, administration, and interpretation ofquestionnaires and tests concerning workers' data, as well as the outcome of such negotiations. The
organization can report how it keeps worker representatives informed and involved in developing dataand privacy policies regarding processing and monitoring personal data. Examples of how worker
representatives can be involved include consultation prior to the launch or change of automatedsystems that process personal data of the workers, consultation before the introduction of electronicmonitoring of workers’ activities, and consultation on performance tests that workers need tocomplete.

Page 17 of 34

520

Disclosure EMPL 6 Termination policies

521

REQUIREMENTS

522

The organization shall:

523
524

a. describe its termination policy for employees and workers who are not employees
including:

525

526

i.
ii.
iii.
iv.

the valid reasons for termination listed in the policy;
the procedure for termination for each reason for termination;
any safeguards against wrongful and unfair termination;
the procedure for appeal against termination.

527

GUIDANCE

528
529

In this disclosure, termination refers to the cessation of employment or work initiated by theorganization. The termination policy is related to the job security of a worker.

530
531

Organizations should separately report the information in EMPL 6-a-i to iv for employees and workers
who are not employees.

532
533
534
535

The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

536

Guidance to EMPL 6-a-i

537
538
539

According to the ILO’s Termination of Employment Convention, 1982 (No. 158) [4], work is terminatedwhen it is related to misconduct or underperformance of the worker or in cases of significant
operational changes. See also GRI SICH: Significant Changes for Workers 202X.

540
541
542
543
544
545
546
547
548
549

The following do not constitute valid reasons for termination:• union membership or participation in union activities outside working hours or, with theconsent of the employer, within working hours;• seeking office as, or acting or having acted in the capacity of, a workers' representative;• filing a complaint or participating in proceedings against an employer involving an alleged
violation of laws or regulations, or recourse to competent administrative authorities;• race, color, sex, gender, marital status, family responsibilities, religion, political opinion,
national extraction, or social origin;• pregnancy, absence from work during maternity leave;• temporary absence from work because of injury or ill health.

550

Guidance to EMPL 6-a-ii

551
552

The procedure for termination can vary, depending on whether it is for misconduct,
underperformance, or termination due to the introduction of significant changes in the organization.

553
554
555
556

Under requirement SICH 1-a in GRI SICH: Significant changes for workers 202X any instances ofmass termination due to significant changes affecting employees and workers who are not employees
must be reported by the organization. Additionally, measures to mitigate the negative impacts of suchsignificant changes should also be included in the report.

557

Guidance to EMPL 6-a-iv

558
559

When describing the procedure for appeal against termination, organizations can explain the different
authorities that receive appeals and the period after termination during which the worker can appeal.

Page 18 of 34

560

2. Topic disclosures

561
562
563

An organization reporting in accordance with the GRI Standards is required to report any disclosuresfrom this section (Disclosure EMPL 7 through Disclosure EMPL 10) that are relevant to its
employment-related impacts.

564

Disclosure EMPL 7 New hires and turnover

565

REQUIREMENTS

566

The organization shall:

567
568

a. report the total number and ratio of new employees recruited, and a breakdown of this total
by:

569
570
571
572
573
574

i.
ii.
iii.
iv.

employee type;age group;
gender;region;b. report the total number and percentage of employee turnover, and a breakdown of thistotal by:

575
576
577
578

i.
ii.
iii.
iv.

employee type;age group;
gender;region;579

c. describe the most common reasons for voluntary turnover;580

d. describe the most common reasons for termination of employment;

581
582

e. report the internal recruitment rate of internal recruitment rate for open positions from
employees and workers who are not employees;

583

f.

584
585
586
587

report the number of employees by length of tenure, and a breakdown by region, for:
i.
ii.
iii.
iv.

full-time employees;
part-time employees;
non-guaranteed hours employees;
temporary employees;

588
589

g. report the total number and turnover rate of the most common types of workers who are
not employees, and a breakdown of this total by region;

590
591
592

h. report contextual information necessary to understand the data reported under EMPL 7-a-g
and describe the methodologies and assumptions used to compile the data, including
whether the numbers are reported:

593
594
595

i. in headcount, full-time equivalent (FTE), or using another methodology;
ii. at the end of the reporting period, as an average across the reporting period, or using
another methodology.

596

GUIDANCE

597
598
599
600
601

This disclosure provides information on the organization's recruitment process, including internal andexternal recruitment, employee turnover, and tenure. It covers the recruitment of various employee
types, such as full-time, part-time, non-guaranteed hours, and temporary employees. Internal
recruitment is the process of filling job vacancies within an organization by considering existing
employees for the available positions rather than seeking candidates externally.

602
603
604

The employee turnover rate provides insight into an organization's workplace culture. A high turnoverrate may indicate worker dissatisfaction, poor management, or inadequate employee engagement. By
monitoring the turnover rate, companies can identify areas for improvement and create a more

Page 19 of 34

605
606

positive work environment. Additionally, understanding employee length of tenure can give an idea ofthe organization's stability.

607
608
609
610

The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

611

Guidance to EMPL 7-a and EMPL 7-b

612
613
614

This information can signify the organization’s efforts to implement inclusive recruitment practices
based on age and gender. The organization can also report the rate of new employees recruited bygroups of workers, such as employees with disabilities.

615

The rate of new employees recruited can be calculated using the following formula:
Rate of new
employees
recruited

New employees recruited at the end of the reporting period=

Total number of employees at the start of the reporting
period

X 100

617
618

Disclosure 2-7 in GRI 2: General Disclosures 2021 identifies the total number of employees. See therecommendation in clause 2.2 in Disclosure 401-1.

619
620
621
622

It can also signal a fundamental change in the organization’s core operations structure. An uneventurnover by age or gender can indicate potential inequity in the workplace. An organization can report
if they use a permanent-to-temporary worker ratio in their planning. The organization should report its
applied methodology and whether headcount or FTE is used.

623
624
625

If turnover is stable, the organization can report it and show how the turnover rate corresponds to theindustry average. See Table 1 for an example of how to present the information on EMPL 7-a and
EMPL 7-b.

626
627

Table 1. Example template for presenting information on employee recruitment rate andturnover rate by employee type, age group, gender and region
Number of new
employees
recruited

Rate of new
employees
recruited

Total employee
turnoverRate ofemployeeturnover

Employee type
Permanent
employees
Temporaryemployees
Full-time employees
Part-time
employees
Non-guaranteed
hours employees
Age group< 20 years
20 ≤ age < 30 years
31 ≤ age ≤ 50 years>50 years oldPage 20 of 34

Gender
Men
Women
Other*
Not disclosed**
RegionRegion A
Region B
Region C
Region D
628* Gender is specified by the employees themselves.

629** Gender is not disclosed by the employees themselves.

630

Guidance to EMPL 7-a-i and EMPL 7-b-i

631
632
633

Employee type refers to the different types of employees reported under requirement 2-7-b in GRI 2:
permanent employees, temporary employees, non-guaranteed hours employees, full-time employees,
and part-time employees.

634

Guidance to EMPL 7-a-ii and EMPL 7-b-ii

635
636
637
638
639

The organization should use the following age groups:• Under 20 years old;
• 20-30 years old;
• 31-50 years old;
• Over 50 years old.

640

Guidance to EMPL 7-a-ii and EMPL 7-b-ii

641
642
643

The organization is free to choose how to report the breakdown by gender. It is not required to report
the four categories suggested in Table 1. For example, instead of an ‘other’ category, the organization
can report any gender category specified by employees.

644

Guidance to EMPL 7-c

645

Voluntary turnover refers to resignations given by employees.

646

Guidance to EMPL 7-e

647
648

Internal recruitment refers to new vacancies within the organization being filled by existing employees
and workers who are not employees, rather than external hires.

649
650

The organization should use the following formula to calculate the internal recruitment rate and report
it as a percentage:
Total number of open vacancies filled by internal
recruitment
Internal recruitment rate=
Total number of open vacancies filled by internal andexternal recruitment

651

Guidance to EMPL 7-f

652
653
654

The length of tenure is the time employees are employed by the organization. When calculating
tenure, the organization uses headcount. The organization can also report how this compares withaverages within its industry or sector.

655

See Table 2 for an example of how to present the information on EMPL 7-f-i to EMPL 7-f-iv.

Page 21 of 34

656
657

Table 2. Example template for presenting information on length of tenure by employee typeand region
Region B

Region A
Employeelength oftenureFulltime
employees

Parttime
employees

Nonguarant
eed
hours
employees

Temporary
employees

Fulltime
employees

Parttime
employees

Nonguarant
eed
hours
employees

Temporary
employeesLess than 1month
1 month to lessthan 6 months
6 months toless than 12
months1 year to lessthan 3 years
3 years to lessthan 5 years
5 years to lessthan 10 years
More than 10
years
658

Guidance to EMPL 7-g

659

See Table 4 for an example of how to present the information for EMPL-7-g.

660
661

Table 4. An example template for presenting information reports the total number and turnoverrate of the most common types of workers who are not employees.
Most common type ofworkers who are not
employees 1

Most common type ofworkers who are not
employees 2

Most common type ofworkers who are not
employees 3

Number ofworkerturnoverNumberof worker
turnoverNumberof worker
turnoverRate ofworkerturnoverRate ofworkerturnoverRate ofworkerturnoverRegionRegion A
Region B
Region C
Region D
Total
662

Percentage change in employee types

663
664
665

The following provides guidance for organizations on reporting the percentage change for thefollowing employee types: full-time employees, temporary employees, non-guaranteed hours
employees, part-time employees, and permanent employees. It also gives additional breakdowns by

Page 22 of 34

666
667

gender and region for each employee type. The organization is not required to comply with thisguidance.

668

The percentage change of employees by employee type is calculated using the following formula:
Percentagechange of
employees by
employee type

Number of employees by type at the end of the reporting
period – Number of employees by type at the start of thereporting period=

X 100
Number of employees by type at the start of the reporting
period670

The percentage change of employees by region is calculated using the following formula:
Percentagechange of
employees byregionNumber of employees by region at the end of the reporting
period – Number of employees by region at the start of thereporting period=

X 100
Number of employees by region at the start of the reporting
period671

The percentage change of employees by gender is calculated using the following formula:
Percentagechange of
employees bygenderNumber of employees by gender at the end of the reporting
period – Number of employees by gender at the start of thereporting period=

X 100
Number of employees by gender at the start of the reporting
period672

See Table 5 and Table 6 for examples of how to present the above information.

Page 23 of 34

673
674

Table 5: Example template for presenting information on change in percentage of employees
by gender
Total % percentagechange% change by gender
Men

Women

Other*

Not
disclosed**

Full-time
employees
Temporaryemployees
Nonguaranteed
hours
employees
Part-time
employees
Permanent
employees
675* Gender is specified by the employees themselves.

676** Gender is not disclosed by the employees themselves.

677
678
679

The organization is free to choose how to report the breakdown by gender. It is not required to report
the four categories suggested in Table 5. For example, instead of an ‘other’ category, the organization
can report any gender category specified by employees.

680
681

Table 6. Example template for presenting information on change in percentage of employees
by region
Total % percentagechange% change by region
Region A

Region B

Region C

Region D

Full-time
employees
Temporaryemployees
Nonguaranteed
hours
employees
Part-time
employees
Permanent
employees

Page 24 of 34

682

Job satisfaction

683
684
685
686

Job satisfaction can benefit organizations by reducing worker turnover and increasing productivity
levels. The following provides guidance for organizations on how to report job satisfaction for
employees and workers who are not employees, as well as other aspects of well-being. Organizations
are not required to comply with this guidance.

687
688
689

The measure of job satisfaction is the percentage of those who are overall satisfied with their job, or
the average value of job satisfaction, on a scale from 0 to 10. The following calculations can be used
to calculate job satisfaction:

690

See reference [17] in the Bibliography.

Satisfaction rate of workers=

Number of workers reporting ‘Satisfied’ or ‘Very satisfied’ inresponse to the question ‘How satisfied are you with yourjob?’
Total number of workers

Average level of job
satisfaction

Average value on a scale from 0 to 10, in response to thequestion ‘How satisfied are you with your job?’=
Total number of workers

691
692
693
694
695
696
697
698

When reporting job satisfaction, the organization should explain the methodology, tools, and time
periods used to collect the data. The organization should also report the number and share of workers
that completed the survey, including employment types or categories excluded, as well as the
response rate. The organization should also report if surveys are anonymous and how it ensures
there is no retaliation for workers providing their opinions. The organization can report how theoutputs of the worker satisfaction survey have improved recruitment, onboarding, training, andperformance management. The organization can also report if there has been any evidence ofimprovements in job satisfaction because of implemented changes.

699

The organization can supplement the worker satisfaction rate with additional indicators, such as:

700
701
702
703
704
705
706

•
•
•

Perceptions of the quality of the working environment, such as job security, opportunities forcareer advancement, autonomy, emotional and physical demands, and social support. Seereference [18] in the Bibliography.
Additional questions on workplace well-being, such as happiness, meaning, and stress atwork. See reference [8] in the Bibliography.
Early termination rate, such as workers who terminate the employment relationship and leave
before the final day of a temporary contract.

Page 25 of 34

707

Disclosure EMPL 8 Incidents related to recruitment

708

REQUIREMENTS709

The organization shall:

710

a. report the total number and type of incidents related to recruitment;

711
712

b. describe the actions taken or planned to address each type of incident related torecruitment, including:

713
714

i. providing for or cooperating in the remediation of incidents;
ii. preventing incidents in the future.

715

GUIDANCE

716
717
718
719
720
721
722
723
724
725

In the context of this disclosure, an ‘incident’ refers to a legal action or complaint registered with thereporting organization or competent authorities through a formal process, or an instance of noncompliance identified by the organization through established procedures. Established procedures to
identify instances of non-compliance can include management system audits, formal monitoring
programs, or grievance mechanisms. These procedures, such as a code of conduct or businessprinciples, are usually embedded in the organization’s management system. Incidents related torecruitment refer to breaches in the organization's recruitment policy when hiring directly or indirectly.
Examples of incidents can include job seekers being charged recruitment fees, jobseekers being
asked if they are pregnant or intend to have children, job advertisements stating that women should
not apply, or confiscating workers’ passports by a temporary work agency.

726
727

The scope of this disclosure includes employees, workers who are not employees and who are
directly or indirectly recruited by the organization, job seekers, and former workers of the organization.

728
729

If the organization cannot disclose specific information (e.g., because of workers' right to privacy), it
can provide the information in aggregated or anonymized form.

730
731
732
733

The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

734

Guidance to EMPL 8-a

735

See Table 7 for an example of how to present the information on EMPL 8-a.

736

Table 7. Example template for presenting information on incidents related to recruitment
Significant location ofoperation

Number ofincidents

Type of incidents

Remediation
actions
were taken

Preventative
actions
were taken

Region A
Region B
Region C
Region D
Total

Page 26 of 34

738

Disclosure EMPL 9 Performance reviews

739

REQUIREMENTS

740

The organization shall:

741
742

a. report the percentage of employees who received a performance review during thereporting period by:

743
744

i. employee category;ii. gender;

745
746

b. report in headcount the total number of workers who are not employees who received aperformance review during the reporting period;

747
748

c. report the reasons why employees and workers who are not employees did not receive a
performance review;749

d. report the number of appeals submitted regarding the performance management system.

750

GUIDANCE

751
752
753
754
755

This disclosure measures the extent to which the organization reviews the performance of all its
employees and workers who are not employees as part of performance management. Performance
reviews are usually meetings between the worker and the organization's management to discuss theevaluation of the worker’s performance, the type of work they conduct, possible training, futureobjectives, and career development opportunities.

756
757
758
759

The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

760

Guidance to EMPL-9-a

761
762

This requirement demonstrates the extent to which performance reviews are applied throughout theorganization and whether there is equal access to the performance review process.

763
764

The organization should use data from Disclosure 2-7 in GRI 2: General Disclosures 2021 to identify
the total number of employees by gender.

765

The information required can be presented using the following template:

766
767

Table 8. Example template for presenting information on employees who received an annual
performance review.
Percentage of total employees who received aperformance review
Employee category
Employee category 1
Employee category 2
Employee category 3
GenderMen
Women
Other*
Not disclosed**
Total

Page 27 of 34

769*Gender as specified by the employees themselves.

770**Gender is not disclosed by the employees themselves.

771
772
773

The organization can report the percentage of employees who received a performance review andwere subsequently rewarded or recognized with outcomes such as promotions, additional leave,training or education opportunities, and cash bonuses.

774
775
776
777

The organization can report the percentage of employees with an unsatisfactory performance review
and plan for improvement, as well as the subsequent outcome, such as continued employment or
termination. The organization can report the average period an employee has to improve theirperformance in performance improvement plans.

778

Guidance to EMPL 9-a-i

779
780

The percentage of employees who received a performance review during the reporting period byemployee category is calculated using the following formula:
Percentage of
employees who
received aperformance review
per employee
category

In headcount, the total number of employees who
received a performance review during the reporting
period in a given employee category=

X 100
In headcount, the total number of employees in theemployee category in the reporting period

782
783
784

The breakdown by employee category covers a breakdown of employees by level, such as senior andmiddle management. This information is derived from the organization’s own human resources
system.

785

Guidance to EMPL 9-a-ii

786
787

The percentage of employees who received a performance review during the reporting period bygender is calculated using the following formula:
Percentage of
employees who
received aperformance review
per gender

In headcount, the total number of employees bygender who received a performance review during
the reporting period=

X 100
In headcount, the total number of employees bygender in the reporting period

789
790
791
792

The organization is free to choose how to report the breakdown by gender. It is not required to report
the four categories suggested in Table 8. For example, instead of an ‘other’ category, the organization
can report any gender category specified by employees. The organization can report as many
additional gender categories as specified by the employees themselves.

793

Guidance to EMPL 9-d

794
795
796

Appeals regarding the performance management system can be due to the outcome or the processitself. The organization can report the outcomes of these appeals or the days it took to resolve theappeals.

Page 28 of 34

798

Disclosure EMPL 10 Incidents related to personal dataprotection and privacy

799

REQUIREMENTS

800

The organization shall:

801
802

a. report the number and types of incidents related to personal data protection and privacyof employees and workers who are not employees;

803
804

b. describe the actions taken or planned to address each type of incident related to personal
data protection and privacy of employees and workers who are not employees, including:

797

805
806

i. providing for or cooperating in the remediation of incidents;
ii. preventing incidents in the future.

807

GUIDANCE

808
809
810
811
812

In the context of this disclosure, an ‘incident’ refers to a legal action or complaint registered with thereporting organization or competent authorities through a formal process or an instance of noncompliance identified by the organization through established procedures. Established procedures to
identify instances of non-compliance can include management system audits, formal monitoring
programs, or grievance mechanisms.

813
814

Personal data protection and worker privacy incidents can include data leaks to third parties or otherindividuals in the organization who do not have prior authorization.

815
816

If the organization cannot disclose specific information (e.g., due to workers' right to privacy), it can
provide the information in aggregated or anonymized form.

817
818

The scope of this disclosure is also for employees and workers who have left the organization andjobseekers.

819
820
821
822

The scope of this Standard is the organization's employees and workers who are not employees andwhose work is controlled by the organization, hereinafter ‘workers who are not employees’. Control ofwork implies that the organization directs the work performed or controls the means or methods for
performing the work. See the Control of Work Standard Interpretation to GRI 2 for more information.

823

Guidance to EMPL 10-a824

See Table 9 for an example of how to present the information on EMPL 10-a.

825
826

Table 9. Example template for presenting information on incidents related to personal dataprotection and workers' privacy
Significant location ofoperation

Number ofincidents

Type ofincidents

Remediation
actions were
taken

Preventative
actions were
taken

Region A
Region B
Region C
Region D
Total

Page 29 of 34

828

Glossary

829
830This glossary provides definitions for terms used in this Standard. The organization is required toapply these definitions when using the GRI Standards.

831
832
833
834

The definitions included in this glossary may contain terms that are further defined in the complete
GRI Standards Glossary. All defined terms are underlined. If a term is not defined in this glossary or in
the complete GRI Standards Glossary, definitions that are commonly used and understood apply.

835
836
837
838
839
840
841

collective bargaining
all negotiations that take place between one or more employers or employers’ organizations, on the
one hand, and one or more workers’ organizations (e.g., trade unions), on the other, for determining
working conditions and terms of employment or for regulating relations between employers andworkers
Source:International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No.
154); modified

842
843
844
845
846

employeeindividual who is in an employment relationship with the organization according to national law orpractice

847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
862
863
864
865
866
867
868
869
870
871

employee category
breakdown of employees by level (such as senior management, middle management) and function(such as technical, administrative, production)
Note:
This information is derived from the organization’s own human resources system.

employee turnover
employees who leave the organization voluntarily or due to dismissal, retirement, or death in service
forced or compulsory labor
all work and service that is exacted from any person under the menace of any penalty and for which
the said person has not offered herself or himself voluntarily
Source:International Labour Organization (ILO), Forced Labour Convention, 1930 (No. 29);
modified
Note 1:
The most extreme examples of forced or compulsory labor are slave labor andbonded labor, but debts can also be used as a means of maintaining workers in astate of forced labor.
Note 2:
Indicators of forced labor include withholding identity papers, requiring compulsory
deposits, and compelling workers, under threat of firing, to work extra hours to which
they have not previously agreed.
freedom of associationright of employers and workers to form, to join and to run their own organizations without priorauthorization or interference by the state or any other entity
full-time employee
employee whose working hours per week, month, or year are defined according to national law
or practice regarding working time

Page 30 of 34

872
873
874
875
876
877
878
879
880
881
882
883
884
885
886
887
888
889
890
891
892
893
894
895
896
897
898
899
900
901
902
903
904
905
906
907
908
909
910
911
912
913
914
915
916
917
918
919
920
921
922
923
924
925
926
927
928

grievance mechanism
routinized process through which grievances can be raised and remedy can be sought
Source:United Nations (UN), Guiding Principles on Business and Human Rights:
Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011;
modified
Note:
See Guidance to Disclosure 2-25 in GRI 2: General Disclosures 2021 for more
information on ‘grievance mechanism’
human rights
rights inherent to all human beings, which include, at a minimum, the rights set out in the United
Nations (UN) International Bill of Human Rights and the principles concerning fundamental
rights set out in the International Labour Organization (ILO) Declaration on Fundamental
Principles and Rights at Work
Source:United Nations (UN), Guiding Principles on Business and Human Rights:
Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011;
modified
Note:
See Guidance to 2-23-b-I in GRI 2: General Disclosures 2021 for more informationon ‘human rights’.
impacteffect the organization has or could have on the economy, environment, and people, including on
their human rights, which in turn can indicate its contribution (negative or positive) to sustainable
development
Note 1:
Impacts can be actual or potential, negative or positive, short-term or long-term,
intended or unintended, and reversible or irreversible.
Note 2:
See section 2.1 in GRI 1: Foundation 2021 for more information on ‘impact’.
non-guaranteed hours employee
employee who is not guaranteed a minimum or fixed number of working hours per day, week, ormonth, but who may need to make themselves available for work as required
Source:ShareAction, Workforce Disclosure Initiative Survey Guidance Document, 2020;
modified
Examples:casual employees, employees with zero-hour contracts, on-call employees
parental leave
leave granted to men and women employees on the grounds of the birth of a childpart-time employee
employee whose working hours per week, month, or year are less than the number of working
hours for full-time employees
permanent employee
employee with a contract for an indeterminate period (i.e., indefinite contract) for full-time or part-time
workreporting period
specific time period covered by the reported information
Examples:fiscal year, calendar year
remedy / remediationmeans to counteract or make good a negative impact or provision of remedy
Source:United Nations (UN), The Corporate Responsibility to Respect Human Rights: An
Interpretive Guide, 2012; modified
Examples:apologies, financial or non-financial compensation, prevention of harm throughinjunctions or guarantees of non-repetition, punitive sanctions (whether criminal oradministrative, such as fines), restitution, restoration, rehabilitation

Page 31 of 34

929
930
931
932
933
934
935
936
937
938
939
940
941

significant change
alteration to the organization’s pattern of operations that can potentially have significant positiveor negative impacts on workers performing the organization’s activities
Examples:closures, expansions, mergers, new openings, outsourcing of operations,
restructuring, sale of all or part of the organization, takeovers

942
943
944
945
946
947
948
949
950
951
952
953
954
955
956
957
958
959
960
961
962
963
964
965
966
967
968
969
970
971
972
973
974
975
976
977
978
979
980
981
982
983
984
985
986

group of individuals with a specific condition or characteristic (e.g., economic, physical, political,
social) that could experience negative impacts as a result of the organization’s activities more
severely than the general population
Examples:children and youth; elderly persons; ex-combatants; HIV/AIDS-affected households;
human rights defenders; indigenous peoples; internally displaced persons;migrant workers and their families; national or ethnic, religious and linguistic
minorities; persons who might be discriminated against based on their sexual
orientation, gender identity, gender expression, or sex characteristics (e.g., lesbian,gay, bisexual, transgender, intersex); persons with disabilities; refugees orreturning refugees; women
Note:
Vulnerabilities and impacts can differ by gender.

temporary employee
employee with a contract for a limited period (i.e., fixed term contract) that ends when the specifictime period expires, or when the specific task or event that has an attached time estimate iscompleted (e.g., the end of a project or return of replaced employees)
vulnerable group

workerperson that performs work for the organization
Examples:
employees, agency workers, apprentices, contractors, home workers, interns, self
employed persons, sub-contractors, volunteers, and persons working fororganizations other than the reporting organization, such as for suppliers
Note:
In the GRI Standards, in some cases, it is specified whether a particular subset ofworkers is required to be used.
worker consultation
seeking of workers’ views before making a decision
Note 1:
Worker consultation might be carried out through workers’ representatives.
Note 2:
Consultation is a formal process, whereby management takes the views of workers
into account when making a decision. Therefore, consultation needs to take place
before the decision is made. It is essential to provide timely information to workers
or their representatives in order for them to provide meaningful and effective input
before decisions are made. Genuine consultation involves dialogue.
Note 3:
Worker participation and worker consultation are two distinct terms with specificmeanings. See definition of ‘worker participation’.
worker participation
workers’ involvement in decision-making
Note 1:
Worker participation might be carried out through workers’ representatives.
Note 2:Worker participation and worker consultation are two distinct terms with specificmeanings. See definition of ‘worker consultation’.
worker representative
person who is recognized as such under national law or practice, whether they are:• a trade union representative, namely, a representative designated or elected by trade unions
or by members of such unions; or• an elected representative, namely, a representative who is freely elected by the workers of
the undertaking in accordance with provisions of national laws, regulations, or collective
agreements, whose functions do not include activities which are recognized as the exclusive
prerogative of trade unions in the country concerned.

Page 32 of 34

987
988
989
990
991
992
993
994

995
996
997
998
999
1000
1001
1002
1003
1004
1005
1006
1007
1008
1009
1010
1011
1012
1013
1014
1015
1016
1017
1018
1019
1020
1021
1022
1023
1024
1025
1026
1027
1028
1029
1030
1031
1032
1033
1034

Source:International Labour Organization (ILO), Workers' Representatives Convention, 1971
(No. 135)

workers who are not employees
Workers who are not in an employment relationship with the organization but are not in an
employment relationship with the organization, but whose work is controlled by theorganization. Control of work implies that the organization directs the work performed
or controls the means or methods for performing the work.
Note 1: the type of contractual relationship between the organization and the worker (e.g.,
employment agency, contractor) does not determine whether the organization
controls the work.
Examples: agency workers, apprentices, contractors, home workers, interns, self-employed persons,sub-contractors, and volunteers.

work-related injury or ill healthnegative impacts on health arising from exposure to hazards at work
Source:International Labour Organization (ILO), Guidelines on Occupational Safety and
Health Management Systems, ILO-OSH 2001, 2001; modified
Note 1:‘Ill health’ indicates damage to health and includes diseases, illnesses, anddisorders. The terms ‘disease’, ‘illness’, and ‘disorder’ are often usedinterchangeably and refer to conditions with specific symptoms and diagnoses.
Note 2:Work-related injuries and ill health are those that arise from exposure to hazards atwork. Other types of incident can occur that are not connected with the work itself.
For example, the following incidents are not considered to be work related:o a worker suffers a heart attack while at work that is unconnected with work;o a worker driving to or from work is injured in a car accident (where driving is notpart of the work, and where the transport has not been organized by theemployer);o a worker with epilepsy has a seizure at work that is unconnected with work.
Note 3:Note 4:

Traveling for work: Injuries and ill health that occur while a worker is traveling arework related if, at the time of the injury or ill health, the worker was engaged in work
activities ‘in the interest of the employer’. Examples of such activities include
traveling to and from customer contacts; conducting job tasks; and entertaining or
being entertained to transact, discuss, or promote business (at the direction of theemployer).
Working at home: Injuries and ill health that occur when working at home are work
related if the injury or ill health occurs while the worker is performing work at home,
and the injury or ill health is directly related to the performance of work rather than
the general home environment or setting.
Mental illness: A mental illness is considered to be work related if it has been
notified voluntarily by the worker and is supported by an opinion from a licensed
healthcare professional with appropriate training and experience stating that theillness is work related.
For more guidance on determining ‘work-relatedness’, see the United States
Occupational Safety and Health Administration, Determination of work-relatedness
1904.5, https://www.osha.gov/pls/ oshaweb/owadisp.show_document?
p_table=STANDARDS&p_id=9636, accessed on 1 June 2018.
The terms ‘occupational’ and ‘work-related’ are often used interchangeably.

Page 33 of 34

1035

Bibliography

1036
1037

This section lists authoritative intergovernmental instruments and additional references used indeveloping this Standard.

1038
1039
1040
1041
1042
1043
1044
1045
1046
1047
1048
1049
1050
1051
1052
1053

Authoritative instruments:
1. International Labour Organization (ILO), Employment Relationship Recommendation, 2006,(No. 198).
2. International Labour Organization (ILO), Quality Apprenticeships Recommendation, 2023,(No. 208).
3. International Labour Organization (ILO), Private Employment Agencies Convention, 1997,(No.181).
4. International Labour Organization (ILO), Termination of Employment Convention, 1982 (No.
158).
5. International Labour Organization (ILO), Termination of Employment Recommendation, 1982
(No. 166).
6. International Labour Organization (ILO), Human Resources Development Recommendation,
2004, (No. 195).
7. International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at
Work, 2022.

1054
1055
1056
1057
1058
1059
1060
1061
1062
1063
1064
1065
1066
1067
1068
1069
1070
1071
1072
1073
1074
1075

Additional references:
8. De Neve, J-E. and Ward, G. Measuring Workplace Well-being, University of Oxford Wellbeing Research Center Working Paper 2303, 2023.
9. International Labour Organization (ILO), General Principles and Operational Guidelines for
Fair Recruitment, 2019.
10. International Labour Organization (ILO), Private Employment Agencies Recommendation,
1997, (No.188).
11. International Labour Organization (ILO), Non-standard employment around the world:
Understanding challenges, shaping prospects, 2016.
12. International Labour Organization (ILO), Part-Time Work Convention, 1994 (No. 175).
13. International Labour Organization (ILO), Part-Time Work Recommendation, 1994 (No. 182).
14. International Labour Organization (ILO), The Employment Relationship: An annotated guide
to ILO Recommendation No. 198, 2007.
15. International Labour Organization (ILO), Note on Convention No. 158 and Recommendation
No. 166 concerning termination of employment, 2009.
16. International Labour Organization (ILO), Protection of workers’ personal data, 1997.
17. Organisation for Economic Co-operation and Development (OECD), Guidelines on Measuring
Subjective Well-being, pp. 262, 2013.
18. Organisation for Economic Co-operation and Development (OECD), Guidelines on Measuring
the Quality of the Working Environment, 2017.
19. International Labour Organization (ILO), Code of Practice on Protection of worker's personaldata, 1997.

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