gssbsecretariat@globalreporting.org

Item 05 – GRI Topic Standard Projectfor Labor – Control of Work Standard
Interpretation to GRI 2 – Exposure
draftFor GSSB approval
Date26 April 2024

Meeting16 May 2024

Project

GRI Topic Standard Project for Labor

Description

This document sets out the exposure draft of the GRI Control of Work Standard
Interpretation to GRI 2 Standard. These are submitted for GSSB approval for
public exposure.
If approved, it is proposed that public exposure commence in early June and run
until late 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. TheGSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2024

1Standard Interpretations

2Standard Interpretation 1 to GRI 2: General disclosures 2021, Control of work.

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Responsibility

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6This Standard Interpretation is issued by the Global Sustainability Standards Board (GSSB). Any
feedback on the GRI Standards and related Interpretations can be submitted togssbsecretariat@globalreporting.org for consideration by the GSSB.

7Relevant section

8Guidance to 2-8-a for Disclosure 2-8 in GRI 2: General Disclosures 2021

9Issue10111213

Disclosure 2-8 Workers who are not employees in GRI 2: General Disclosures 2021 requiresorganizations to report the total number of workers who are not employees and whose work is
controlled by the organization. This includes describing the most common types of workers, theircontractual relationship with the organization, and the type of work they perform.

14The guidance of 2-8-a states:

1516‘The following are examples of workers who are not employees and whose work is controlled bythe organization. The following workers are included under this disclosure: […]

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Workers of one of the organization’s suppliers, where the organization instructs the supplier touse particular materials or work methods to manufacture the products or deliver the services.’

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Feedback from users of the GRI Standards suggests it is unclear whether organizations shouldclassify workers in their business relationships as workers who are not employees when giving them
instructions regarding product or service specifications to their business relationships. This ambiguity
is between an example in the guidance of 2-8-a (instructing a supplier to use specific materials orwork methods to manufacture the products or deliver the services) and the concept of giving
instructions regarding product or service specifications to their business relationships.

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Interpretation Statement

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The guidance of Disclosure 2-8-a states:

2728‘The following are examples of workers who are not employees and whose work is controlled bythe organization. The following workers are included under this disclosure: […]29303132333435363738394041424344•

Workers of one of the organization’s suppliers, where the organization instructs the supplier touse particular materials or work methods to manufacture the products or deliver the services.
[..]’

It is important to note that this applies only in situations where the organization controls the work of
the workers in its business relationships, as per the conditions described under ‘Control of work’ inthis Standard Interpretation. When organizations instruct the business relationship with product orservice specifications, this does not necessarily mean the organization has control over the work of
the workers in its business relationships. The following are examples of an organization’s instructions
or terms to its business relationships regarding specific materials or work methods for productmanufacturing or service delivery without constituting direct control of work:•••

A multi-national brand commissions a footwear manufacturer to produce sports shoes tocertain measurements and material specifications.
A retailer requests improved sustainable production practices from its textile suppliers, suchas restrictions on freshwater usage during manufacturing.
A retailer in the purchasing agreement stipulates a certain number of days lead time for its
supplier to fulfill the order and deliver the products.

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•
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A household goods company purchasing team requests one of its furniture suppliers to use
sustainably sourced timber for its products.
A food and beverage company contracts a logistics company to provide services that must
adhere to the contracting company’s safety standards and code of conduct.

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It does not constitute control of the work when an organization provides instructions such as thosethat prevent human rights impacts and ensure decent working conditions. This may involve
implementing guidelines to ensure products and services do not use child labor or excessive working
hours, or clauses in purchase agreements for third-party audits of business relationships’ locations ofoperation to verify compliance with labor standards.

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When reporting disclosures concerning workers who are not employees and whose work is controlled
by the organization, organizations shall use the control of work in conjunction with the guidance of 28-a.

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Additional guidance

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This additional guidance will provide information on the ‘control of work’ concept and howorganizations should apply it. It will also differentiate between the subsets of workers referred to in
GRI Standards.
Control of work

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An organization has control of the work when either one or both of the following conditions are met: if
the organization directs the work performed, or if it has control over the means or methods forperforming the work.

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Firstly, ‘directs the work performed’ refers to organizations determining who performs it, what work isperformed, and when and where it is carried out. For example, hiring workers with specific skill sets,
distributing overtime between workers, and ensuring the work is done personally by the individual.
Assigning a worker a particular task is an example of directing what work is performed. Deciding
when the work is performed involves determining the working time arrangements, such as the numberof working hours, and requiring workers’ availability to be at the organization’s disposal or on standby
to perform the work. Finally, directing where the work is performed includes determining theworkplace where the work must be carried out.

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Secondly, ‘means or methods for performing the work’ refers to organizations determining theapproach to performing work, such as providing instructions, guidelines, tools, materials, andmachinery to complete the work. Examples include the organization providing its workers with raw
materials and machinery and instructing them to follow standard operating procedures for
manufacturing a product or providing workers with a predetermined script to follow when dealing withcustomer telephone calls.

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An organization does not necessarily need to control the physical aspects of the work performed tohave control of the work. Organizations’ ability to control the work may exist even if not exercised,such as when the worker undertakes the work largely or entirely unsupervised. For example, a truck
driver whose work involves driving on public roads, which the organization has no control over, but
the organization still directs the process the driver should follow, such as the time periods products
need to be delivered and the rules, such as the use of a logbook. Another example is when a worker
has a telework arrangement with flexibility about when and where to complete the work.

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Shared control

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Organizations may have sole control of the work or share control with others (e.g., suppliers,
customers, or other business partners, such as joint ventures). Shared control is determined when
there is a contractual relationship between the organization and another entity, and the organization
shares control over the means, methods, or direction of the work performed. Shared control does notmean organizations have less control of the work. Sub-sets of workers in GRI Standards

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GRI defines a worker as a person who performs work for the organization. This includes employees,
agency workers, apprentices, contractors, home workers, interns, self-employed persons, subcontractors, volunteers, and persons working for organizations other than the reporting organization,such as suppliers. In some GRI Standards, it is specified whether the disclosures apply to a particular

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subset of workers. The following are the main subsets of workers covered by the GRI Standards, butthere could be other subsets that an organization can reference.
•Employees

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An employee is an individual who is in an employment relationship with the organization according tonational law or practice. It should be noted that different jurisdictions use various indicators todetermine an employment relationship, such as economic dependency.

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An employee can be further classified as permanent, temporary, non-guaranteed hours, full-time, orpart-time.

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Workers who are not employees

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

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Workers in business relationships work for organizations other than the reporting organization but
perform work for the organization, such as suppliers. The reporting organization does not control theirwork.

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They work for other organizations linked to the organization’s operations, products, or services. These
linkages can be direct business relationships with the organization, often referred to as first-tiersuppliers, or indirect business relationships, often called second- or third-tier suppliers. The types ofworkers in business relationships (no control of work) include self-employed persons, workers ofsuppliers, and workers of entities downstream of the organization’s value chain, such as customers orinvestees, including those beyond the first tier.

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Effective date123

This Standard Interpretation is effective for reports or other materials published on or after [###] 2025.

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