Barbara Strozzilaan 336
1083 HN Amsterdam
The Netherlands
gssbsecretariat@globalreporting.org

Item 03 – GRI Universal Standards
Project – GRI Universal Standards
2021
For GSSB approval
Date

10 May 2021

Meeting

10 June 2021

Project

GRI Universal Standards Project

Description

This document presents the revised GRI Universal Standards, for GSSB approval.
The GRI Universal Standards are structured as follows:•

GRI 1: Foundation 2021 (lines 104-1190)•

GRI 2: General Disclosures 2021 (lines 1191-2899)•

GRI 3: Material Topics 2021 (lines 2900-3994)

A summary of the final changes in the Standards compared to the previous
version shared with the GSSB over the course of January to April 2021 ispresented in the explanatory note at the beginning of the document.
This document reflects the final outcome and consensus of the GRI Human Rights
Technical Committee deliberations.
This document is complemented by Item 04 – GRI Universal Standards Project –Draft GSSB basis for conclusions, which summarizes the significant issues raisedby respondents during public comment and the GSSB responses to these.
Effective dateAs part of this approval, the GSSB is also asked to consider the proposed
effective date of 1 January 2023 (see lines 105, 1192, and 2901) for the revised
Universal Standards.

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 2021

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Contents

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Explanatory note ..................................................................................................................................... 3

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GRI 1: Foundation 2021 .......................................................................................................................... 6

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GRI 2: General Disclosures 2021 ......................................................................................................... 38

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GRI 3: Material Topics 2021 ................................................................................................................. 87

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Explanatory note

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The following significant revisions have been made, including based on latest feedback from the
GSSB and the GRI Human Rights Technical Committee:

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GRI 1: Foundation 2021

10Introduction

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New section added. See lines 146-286.

1. Purpose and system of GRI Standards•

New section added to explain the purpose and the system of GRI Standards. See lines 165286.

2. Key concepts•

Added new guidance under section 2.1 to clarify that the impacts on the economy,
environment, and people are interrelated. See lines 316-320.

3. Reporting in accordance with the GRI Standards

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Revised the description of the ‘not applicable’ reason for omission in Requirement 6 to clarify
that an organization provides this reason when a disclosure or a requirement in a disclosure
does not apply to the organization based on its characteristics (e.g., size, type) but not when
an item does not exist. The organization is required to explain in the GRI content index why
the disclosure or the requirement does not apply to the organization. See lines 601-623.

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Added a clarification in Requirement 6 that when an item specified in a disclosure or in arequirement in a disclosure (e.g., committee, policy, practice, process) does not exist, anorganization can comply with the requirement by reporting this to be the case. It does notneed to provide a reason for omission. The organization can explain the reasons for nothaving this item, or describe any plans to develop it. The organization can choose whether toreport this in the GRI content index or in the report itself. See lines 617-623 and A14-A17.

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Added examples to clarify the difference between the ‘not applicable’ reason for omission, the‘information unavailable / incomplete’ reason for omission, and when an item does not exist.
See lines 603-607, 610-616, and 635-641.

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Removed from the statement of use the reference to the highest governance body, senior
executive, or group of senior executives who review and approve the reported information, as
such reference goes beyond formulating a statement of use of the GRI Standards. Clarified in
the guidance what it means to claim that an organization has reported in accordance with, orwith reference to, the GRI Standards. Added guidance to clarify that an organization reportingin accordance with the GRI Standards is required to report whether the highest governancebody is responsible for reviewing and approving the reported information, including theorganization’s material topics, under Disclosure 2-14 in GRI 2: General Disclosures 2021.
See lines 694-707 and 760-770.

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Updated the requirements for notifying GRI, for both reporting in accordance with the GRI
Standards and for reporting with reference to the GRI Standards. See lines 708-718 and 771781.

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GRI 2: General Disclosures 2021

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Introduction47•

New section added. See lines 1264-1353.

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2. Activities and workers

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Revised requirements ACT-1-b-ii and ACT-1-b-iii for clarity. See lines 1513-1514.

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Revised guidance for requirement ACT-2-a to remove the reference to gender diversity. Seelines 1620-1621.

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Revised guidance for Disclosure ACT-3 to clarify how organizations should report on workers
who are not employees. See lines 1720-1725.

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3. Governance

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Revised the introduction to the full section to clarify the purpose and relevance of governancereporting to sustainability. See lines 1776-1788.

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Removed the following requirement from Disclosure 2-12: ‘the role of any committees of thehighest governance body that have specific responsibilities in relation to these processes’(i.e., the organization’s due diligence and other processes to identify and manage theorganization’s impacts on the economy, environment, and people). This requirement wasrepetitive of requirement 2-9-b: ‘list the committees of the highest governance body that are
responsible for decision-making on and overseeing the management of the organization’s
impacts on the economy, environment, and people’. See lines 1793-1795 and 1852-1866.

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Revised Disclosure 2-14 to clarify the responsibility of the highest governance body withrespect to reviewing and approving the reported information, including the organization’smaterial topics. Added a new requirement for the organization to explain the reason for thehighest governance body not being responsible for reviewing and approving the reported
information, in situations where this is the case. See lines 1890-1899.

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4. Strategy, policies and practices

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Revised Disclosure 2-25 to make clear the difference between ‘grievance mechanisms’ and‘other remediation processes’. The title of the disclosure has been changed to ‘Processes toremediate negative impacts’. See lines 2373-2376 and 2288.

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Revised requirement 2-27-a to report a breakdown of the total number of significant instancesof non-compliance with laws and regulations by instances for which fines were incurred andinstances for which non-monetary sanctions were incurred, to distinguish between the two.
See lines 2458-2461.

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Clarified in guidance to requirement 2-27-a that the scope of the disclosure includes fines thatare being appealed. See lines 2486-2487 and 2492-2494.

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Clarified in guidance to Disclosure 2-27-a that non-monetary sanctions can include directives
to cease or remediate an unlawful activity. See lines 2488-2491.

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GRI 3: Material Topics 2021

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Introduction

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•

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New section added. See lines 2946-3024.

1. Guidance to determine material topics

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Added new guidance for Step 1. Understand the organization’s context, to clarify therecommended scope for the process of determining material topics. See lines 3079-3081.

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Added new Box 5 at the end of section 1, on using the GRI Sector Standards to determinematerial topics. This box includes the guidance which was previously located under
Disclosure 3-2. See lines 3425-3457.

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2. Disclosures on material topics•

Moved the recommendation for the organization to explain – in the absence of applicable
Sector Standards – how it has considered impacts commonly associated with its sectors, andwhether and why any of these impacts have been determined as not material, fromPage 4 of 115

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Disclosure 3-2 to the beginning of the guidance section for Disclosure 3-1. See lines 34833488.

Glossary terms

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Reinstated the reference to sustainable development in the definition of ‘impact’. See lines1088-1091.

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Reinstated the definition of ‘severity (of impacts)’. While this term is not used in therequirements, the concept is central to the determination of materiality and easy to
misunderstand. See lines 1123-1130.

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Other editorial revisions have been made to the text to improve clarity and consistency with the GRI
Style Guide.

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GRI 1: Foundation 2021

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EFFECTIVE DATE: 1 JANUARY 2023

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UNIVERSAL STANDARD

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GRI 1: Foundation 2021

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UNIVERSAL STANDARD

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Effective date

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This Standard is effective for reports or other materials published on or after 1 January 2023. Earlier
adoption is encouraged.

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Responsibility

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This Standard is issued by the Global Sustainability Standards Board (GSSB). Any feedback on the
GRI Standards can be submitted to ???@globalreporting.org for the consideration of the GSSB.

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Legal liability

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This document, designed to promote sustainability reporting, has been developed by the Global
Sustainability Standards Board (GSSB) through a unique multi-stakeholder consultative process
involving representatives from organizations and report information users from around the world.
While the GRI Board of Directors and GSSB encourage use of the GRI Sustainability ReportingStandards (GRI Standards) and related Interpretations by all organizations, the preparation andpublication of reports based fully or partially on the GRI Standards and related Interpretations are thefull responsibility of those producing them. Neither the GRI Board of Directors, GSSB nor Stichting
Global Reporting Initiative (GRI) can assume responsibility for any consequences or damages
resulting directly or indirectly from the use of the GRI Standards and related Interpretations in the
preparation of reports, or the use of reports based on the GRI Standards and related Interpretations.

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Copyright and trademark notice

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This document is copyright-protected by Stichting Global Reporting Initiative (GRI). The reproduction
and distribution of this document for information and/or use in preparing a sustainability report ispermitted without prior permission from GRI. However, neither this document nor any extract from it
may be reproduced, stored, translated, or transferred in any form or by any means (electronic,
mechanical, photocopied, recorded, or otherwise) for any other purpose without prior written
permission from GRI.

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Global Reporting Initiative, GRI and logo, GSSB and logo, and GRI Sustainability ReportingStandards (GRI Standards) and logo are trademarks of Stichting Global Reporting Initiative.

135© 2021 GRI. All rights reserved.

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ISBN 978-90-8866-NNN-N

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Contents

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Introduction ............................................................................................................................................. 9139

1. Purpose and system of GRI Standards .............................................................................................. 9140

2. Key concepts ..................................................................................................................................... 13141

3. Reporting in accordance with the GRI Standards ............................................................................. 16

142

4. Reporting principles .......................................................................................................................... 26

143

5. Additional recommendations for reporting ........................................................................................ 31

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Glossary ................................................................................................................................................ 33

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Bibliography .......................................................................................................................................... 37

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Introduction

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GRI 1: Foundation 2021 introduces the purpose and system of the GRI Sustainability ReportingStandards (GRI Standards) and explains key concepts for sustainability reporting. It also specifies therequirements and reporting principles that organizations must comply with to report in accordancewith the GRI Standards. GRI 1 is the first Standard that organizations should consult to understandhow to report using the GRI Standards.

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GRI 1 is structured as follows:

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Section 1 introduces the purpose and the system of the GRI Standards.

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Section 2 explains the key concepts that are used throughout the GRI Standards.

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Section 3 specifies the requirements for reporting in accordance with the GRI Standards.

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Section 4 specifies the reporting principles, which are fundamental to ensuring the quality of
the reported information.

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Section 5 presents recommendations for the organization to align its sustainability reportingwith other types of reporting and to enhance the credibility of its sustainability reporting.

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The Appendixes provide guidance on how to prepare a GRI content index.

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The Glossary contains defined terms with a specific meaning when used in the GRI
Standards.

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The Bibliography lists authoritative intergovernmental instruments used in developing thisStandard.

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1. Purpose and system of GRI

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Standards

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1.1 Purpose of the GRI Standards

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Organizations, through their activities and business relationships, can have an effect on the economy,
environment, and people, and in turn make negative or positive contributions to sustainable
development. Sustainable development refers to ‘development which meets the needs of the present
without compromising the ability of future generations to meet their own needs’ [8]. The objective ofsustainability reporting using the GRI Sustainability Reporting Standards (GRI Standards) is toprovide transparency on how an organization contributes or aims to contribute to sustainable
development.

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The GRI Standards enable an organization to publicly disclose its most significant impacts on theeconomy, environment, and people, including impacts on their human rights, and how theorganization manages these impacts. This enhances transparency on the organization’s impacts andincreases organizational accountability.

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The Standards contain disclosures that allow an organization to report information about its impacts in
a consistent and credible way. This enhances the global comparability and quality of reported
information on these impacts, which supports information users in making informed assessments anddecisions about the organization’s impacts and contribution to sustainable development.

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The GRI Standards are based on expectations for responsible business conduct set out inauthoritative intergovernmental instruments, such as the Organisation for Economic Co-operation andPage 9 of 115

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Development (OECD) Guidelines for Multinational Enterprises [3] and the United Nations (UN)Guiding Principles on Business and Human Rights [5] (see the Bibliographies of the GRI Standards
for a list of authoritative instruments used in developing the GRI Standards). Information reported
using the GRI Standards can help users assess whether an organization meets the expectations set
out in these instruments. It is important to note that the GRI Standards do not set allocations,thresholds, goals, targets, or any other benchmarks for good or bad performance.

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1.2 Users

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The GRI Standards can be used by any organization – regardless of size, type, geographic location,or reporting experience – to report information about its impacts on the economy, environment, andpeople, including impacts on their human rights.

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The reported information can be used by the organization in its decision-making, for example, whensetting goals and targets, or when assessing and implementing its policies and practices.

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Stakeholders and other information users can use the GRI Standards to understand whatorganizations are expected to report about. Stakeholders can also make use of an organization’sreported information to assess how they are affected or how they could be affected by theorganization’s activities.

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Investors, in particular, can use the reported information to assess an organization’s impacts and how
it integrates sustainable development in its business strategy and model. They can also use thisinformation to identify financial risks and opportunities related to the organization’s impacts and toassess its long-term success. Users other than the organization’s stakeholders, such as academics
and analysts, can also use the reported information for purposes such as research or benchmarking.

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The term ‘information users’ in the GRI Standards refers to all these diverse users of theorganization’s reported information.

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1.3 System of GRI Standards

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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). The Universal Standards are used by all organizations when reporting in accordancewith the GRI Standards. The Sector Standards are used by organizations according to the sectors inwhich they operate, and the Topic Standards are used by each organization according to its list of
material topics.

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Universal Standards: GRI 1, GRI 2 and GRI 3

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An organization begins by consulting GRI 1: Foundation 2021. GRI 1 introduces the purpose andsystem of GRI Standards and explains key concepts for sustainability reporting. It also specifies therequirements and reporting principles that the organization must comply with to report in accordancewith the GRI Standards.

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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. This information gives insight into the profile and scale of the organizationand provides a context for understanding the organization’s impacts.

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GRI 3: Material Topics 2021 provides step-by-step guidance on how to determine material topics. GRI
3 also contains disclosures that the organization uses to report information about its process ofdetermining 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 information to report for the material topics.

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Topic Standards

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The Topic Standards contain disclosures for the organization to report information about its impacts inrelation to particular topics. The Topic Standards cover a wide range of topics. The organization uses
the Topic Standards according to the list of material topics it has determined using GRI 3.

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

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1.4 Using the GRI Standards

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All disclosures in the GRI Standards contain requirements. The requirements list information that anorganization must report or provide instructions that the organization must comply with to report inaccordance with the GRI Standards.

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

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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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Requirements, guidance and defined terms

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The following apply throughout the GRI Standards:

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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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Reporting format

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The term ‘sustainability reporting’, in the GRI Standards, refers to the process of reporting, whichstarts with an organization determining its material topics based on its most significant impacts, andresults in the organization publicly reporting information about these impacts.

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The organization can publish or make information accessible in a range of formats (e.g., electronic,
paper-based) across one or more locations (e.g., a standalone sustainability report, web pages, anannual report). The terms ‘report’ and ‘reported information’ in the GRI Standards both refer toinformation reported across all locations.

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The GRI content index provides an overview of the organization’s reported information and shows thelocation where information users can find it. The content index also shows which GRI Standards anddisclosures the organization has used.

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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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Effective date

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All GRI Standards have an effective date. This is the date from when the information published by anorganization must make use of a particular GRI Standard. All information published after the effective
date of a Standard must make use of that Standard.

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For example, GRI 1: Foundation 2021 has an effective date of 1 January 2023. This means that theorganization must make use of GRI 1 for the information it publishes on or after 1 January 2013.

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Effective dates are set keeping in mind that organizations may need time to adopt a new or revisedStandard. Adoption of a Standard before its effective date is encouraged, as this allows theorganization to report according to best practice.

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2. Key concepts

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This section explains the concepts that lay the foundation for sustainability reporting. Understanding
how these concepts are applied in the GRI Standards is essential for those who collect and prepare
information for reporting, as well as for those who interpret information that is reported using theStandards.

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The key concepts covered in this section are: impact, material topic, due diligence, and stakeholder.
The purpose of the Standards is to enable organizations to report information about their mostsignificant impacts on the economy, environment, and people, including impacts on their human rights– in the GRI Standards these are referred to as material topics. Due diligence and stakeholder
engagement help organizations identify their most significant impacts.

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2.1 Impact

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In the GRI Standards, impact refers to the effect an organization has or could have on the economy,
environment, and people, including effects on their human rights, as a result of the organization’s
activities or business relationships. The impacts can be actual or potential, negative or positive, shortterm or long-term, intended or unintended, and reversible or irreversible. These impacts indicate theorganization’s contribution, negative or positive, to sustainable development.

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The organization’s impacts on the economy refer to the impacts on economic systems at local,
national, and global levels. An organization can have an impact on the economy through, for example,
its competition practices, its procurement practices, and its taxes and payments to governments.

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The organization’s impacts on the environment refer to the impacts on living organisms and non-living
elements, including air, land, water, and ecosystems. An organization can have an impact on theenvironment through, for example, its use of energy, land, water, and other natural resources.

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The organization’s impacts on people refer to the impacts on individuals and on groups, such ascommunities, vulnerable groups, or society more generally. This includes the impacts the organization
has on people’s human rights. An organization can have an impact on people through, for example,
its employment practices (e.g., the wages it pays to employees), its supply chain (e.g., the working
conditions of workers of suppliers), and its products and services (e.g., their safety or accessibility).
Individuals or groups that have interests that are affected or could be affected by the organization’s
activities are referred to as stakeholders (see section 2.4 in this Standard for more information).

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The impacts on the economy, environment, and people are interrelated. For example, anorganization’s impacts on the economy and environment can result in impacts on people and their
human rights. Similarly, an organization’s positive impacts can result in negative impacts, and viceversa. For example, an organization's positive impacts on the environment can lead to negative
impacts on people and their human rights.

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2.2 Material topic

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An organization may identify many impacts on which to report. When using the GRI Standards, theorganization prioritizes reporting on those topics that represent its most significant impacts on theeconomy, environment, and people, including impacts on their human rights. In the GRI Standards,
these are the organization’s material topics.

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Examples of material topics are anti-corruption, occupational health and safety, or water andeffluents. A topic need not be limited to only impacts on the economy, or the environment, or people;
it can cover impacts across all three dimensions. For example, an organization might determine that‘water and effluents’ is a material topic, based on the impacts its water use has on ecosystems, aswell as on local communities’ access to water. The GRI Standards group impacts into topics, like‘water and effluents’, to help organizations report in a cohesive way about multiple impacts that relate
to the same topic.

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The process of determining material topics is informed by the organization’s ongoing identification andassessment of impacts. The ongoing identification and assessment of impacts involves engaging with
relevant stakeholders and experts and it is conducted independently of the sustainability reporting
process. See section 1 in GRI 3: Material Topics 2021 for more information on determining material
topics.

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Box 1. Sustainability reporting and financial and value creation reporting

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The GRI Standards enable organizations to report information about the most significant impacts of
their activities and business relationships on the economy, environment, and people, including
impacts on people’s human rights. Such impacts are of primary importance to sustainable
development and to organizations’ stakeholders, and they are the focus of sustainability reporting.

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The impacts of an organization’s activities and business relationships on the economy, environment,
and people can have negative and positive consequences for the organization itself. These
consequences can be operational or reputational, and therefore in many cases financial. For
example, an organization’s high use of non-renewable energy contributes to climate change andcould, at the same time, result in increased operating costs for the organization due to legislation thatseeks to shift energy use toward renewable sources.

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Even if not financially material at the time of reporting, most, if not all, of the impacts of anorganization’s activities and business relationships on the economy, environment, and people will
eventually become financially material issues. The impacts are therefore also important for thoseinterested in the financial performance and long-term success of the organization. Understanding
these impacts is a necessary first step in determining related financially material issues for theorganization.

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Sustainability reporting is therefore crucial for financial and value creation reporting. Information madeavailable through sustainability reporting provides input for identifying financial risks and opportunities
related to the organization’s impacts and for financial valuation. This in turn helps making financial
materiality judgments about what to recognize in financial statements.

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While the impacts of the organization’s activities and business relationships on the economy,
environment, and people may become financially material, sustainability reporting is also highly
relevant in its own right as a public interest activity. Sustainability reporting is independent of theconsideration of financial implications. It is therefore important for the organization to report on all thematerial topics that it has determined using the GRI Standards. These material topics cannot be
deprioritized on the basis of not being considered financially material by the organization.

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2.3 Due diligence

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In the GRI Standards, due diligence refers to the process through which an organization identifies,
prevents, mitigates, and accounts for how it addresses its actual and potential negative impacts on
the economy, environment, and people, including impacts on their human rights. The organization
should address potential negative impacts through prevention or mitigation. It should address actual
negative impacts through remediation, in cases where the organization identifies it has caused orcontributed to those impacts.

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The way the organization is involved with negative impacts (i.e., whether it causes or contributes tothe impacts, or whether the impacts are directly linked by its business relationships) determines how
the organization should address the impacts. It also determines whether the organization has a
responsibility to provide for or cooperate in the remediation of the impacts. The organization should:

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avoid causing or contributing to negative impacts through its own activities, and address suchimpacts when they occur by providing for or cooperating in their remediation throughlegitimate processes;

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in the case of negative impacts that are directly linked to the organization’s operations,products, or services by its business relationships, seek to prevent or mitigate these impacts
even if it has not contributed to them. The organization is not responsible for providing for orcooperating in the remediation of these impacts, but it can play a role in doing so.

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If it is not feasible to address all identified impacts on the economy, environment, and people at once,the organization should prioritize the order in which it addresses potential negative impacts based on
their severity and likelihood. In the case of potential negative human rights impacts, the severity of the
impact takes precedence over its likelihood. See section 1 in GRI 3: Material Topics 2021 for more
information.

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Due diligence is elaborated by the United Nations (UN) Guiding Principles on Business and Human
Rights [5], the Organisation for Economic Co-operation and Development (OECD) Guidelines forMultinational Enterprises [3], and the OECD Due Diligence Guidance for Responsible BusinessConduct [2].

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2.4 Stakeholder

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Stakeholders are individuals or groups that have interests that are affected or could be affected by anorganization’s activities. Common categories of stakeholders for organizations are business partners,
civil society organizations, consumers, customers, employees and other workers, governments, local
communities, non-governmental organizations, shareholders and other investors, suppliers, tradeunions, and vulnerable groups.

398
399
400
401
402
403
404

In the GRI Standards, an interest (or ‘stake’) is something of value to an individual or group, which
can be affected by the activities of an organization. Stakeholders can have more than one interest.
Not all interests are of equal importance and they do not all need to be treated equally. Human rights
have a particular status as an entitlement of all people under international law. The most acuteimpacts the organization can have on people are those that negatively affect their human rights. The
term ‘rightsholders’ is used to refer to stakeholders whose individual human rights or collective rights(held by groups such as indigenous peoples) are or could be affected.

405
406
407

Stakeholder interests can be negatively or positively affected by the organization’s activities. Due
diligence focuses on identifying stakeholder interests that are or could be negatively affected by theorganization’s activities.

408
409
410
411
412
413
414

Stakeholders may not always have a direct relationship with the organization. For example, theworkers in the organization’s supply chain can also be its stakeholders, or there can be individuals orgroups living at a distance from the organization’s operations who can be affected or potentiallyaffected by these operations. They may not be aware that they are stakeholders of that particularorganization, especially if they have not yet been affected by its activities. The organization should
identify the interests of these and other stakeholders who are unable to articulate their views (e.g.,
future generations).

415
416
417
418

Engaging with stakeholders helps the organization identify and manage its negative and positive
impacts. Not all stakeholders will be affected by all activities of the organization. The organization
should identify the stakeholders whose interests have to be taken into account in connection with a
specific activity (i.e., ‘relevant stakeholders’).

419
420
421

Where it is not possible to engage with all relevant stakeholders directly, the organization can engage
with credible stakeholder representatives or proxy organizations (e.g., non-governmentalorganizations, trade unions).

422
423
424

In addition to engaging with stakeholders, the organization can consult with experts in specific issues
or contexts (e.g., academics, non-governmental organizations) for advice on identifying and managing
its impacts.

425
426
427
428
429
430
431
432

Sometimes it is necessary to distinguish between stakeholders whose interests have been affected(i.e., ‘affected stakeholders’), and those whose interests have not yet been affected but could
potentially be affected (i.e., ‘potentially affected stakeholders’). This distinction is important in due
diligence. For example, if an organization’s activity leads to a safety hazard, workers who are injured
because of the hazard are affected stakeholders, and workers who have not yet been injured but whoare exposed to the hazard and could be injured are potentially affected stakeholders. The distinction
between affected and potentially affected stakeholders helps identify which workers should receive
remedy.

433

See reference [2] in the Bibliography.

Page 15 of 115

434

3. Reporting in accordance with the435

GRI Standards

436
437
438
439
440

Reporting in accordance with the GRI Standards enables an organization to provide a comprehensive
picture of its most significant impacts on the economy, environment, and people, including impacts on
their human rights, and how it manages these impacts. This allows information users to makeinformed assessments and decisions about the organization’s impacts and its contribution tosustainable development.

441
442

The organization must comply with all nine requirements in this section to report in accordance with
the GRI Standards.

443

Overview of in accordance requirements
Requirement 1: Apply the reporting principles
Requirement 2: Report the disclosures in GRI 2: General Disclosures 2021
Requirement 3: Determine material topics
Requirement 4: Report the disclosures in GRI 3: Material Topics 2021
Requirement 5: Report disclosures from the GRI Topic Standards for each material topic
Requirement 6: Provide reasons for omission for disclosures and requirements that theorganization cannot comply with
Requirement 7: Publish a GRI content index
Requirement 8: Provide a statement of use
Requirement 9: Notify GRI

444
445
446
447
448

If the organization does not comply with all nine requirements, it cannot claim that it has prepared thereported information in accordance with the GRI Standards. In such a case, the organization may beable to claim that it has prepared the reported information with reference to the GRI Standards,
provided it complies with the requirements specified in ‘Reporting with reference to the GRI
Standards’ at the end of this section.

449

Requirement 1: Apply the reporting principles

450
451

a. The organization shall apply all the reporting principles specified in section 4 of GRI 1:
Foundation 2021.

452
453

Requirement 2: Report the disclosures in GRI 2: General
Disclosures 2021

454

a. The organization shall report all disclosures in GRI 2: General Disclosures 2021.

455

Guidance456

Reasons for omission are permitted for all disclosures in GRI 2 except for:457•

Disclosure 2-1 Organizational details

458•

Disclosure 2-2 Entities included in the organization’s sustainability reporting

Page 16 of 115

459

•

Disclosure 2-3 Reporting period, frequency and contact point

460•

Disclosure 2-4 Restatements of information

461•

Disclosure 2-5 External assurance

462
463
464
465

If the organization cannot comply with a disclosure or with a requirement in a disclosure for which
reasons for omission are permitted, the organization is required to specify in the GRI content index
the disclosure or the requirement it cannot comply with, and to provide a reason for omission and an
explanation. See Requirement 6 in this Standard for more information on reasons for omission.

466

Requirement 3: Determine material topics

467

The organization shall:

468

a. determine its material topics;469

b. review the GRI Sector Standard(s) that apply to its sector(s) and:

470
471

i.

determine whether each topic in the applicable Sector Standard(s) is a material
topic for the organization;

472
473
474

ii.

list in the GRI content index any topics from the applicable Sector Standard(s) thatthe organization has determined as not material and explain why they are notmaterial.

475

Guidance476

See section 1 in GRI 3: Material Topics 2021 for guidance on how to determine material topics.

477

The organization is required to determine its material topics based on its specific circumstances.

478
479

Using the GRI Sector Standards supports the organization in this process. The Sector Standards
provide information for organizations about their likely material topics.

480
481

The organization is required to use the applicable Sector Standards when determining its material
topics.

482

Guidance to 3-b

483
484

The organization is required to comply with Requirement 3-b only if GRI Sector Standards that apply
to its sectors are available.

485
486
487
488
489

The organization is required to review each topic described in the applicable Sector Standards anddetermine whether it is a material topic for the organization. If any of the topics that are included in theapplicable Sector Standards have been determined by the organization as not material, theorganization is required to list them in the GRI content index and explain why they are not material.
See Requirement 7 in this Standard for more information on the content index.

490
491

See section 1 in GRI 3 and the GRI Sector Standards for guidance on how to use the Sector
Standards to determine material topics.

492
493

Requirement 4: Report the disclosures in GRI 3: Material Topics
2021

494

The organization shall:

495

a. report its process of determining material topics using Disclosure 3-1;

496

b. report a list of its material topics using Disclosure 3-2;

Page 17 of 115

497

c. report how it manages each material topic using Disclosure 3-3.

498

Guidance499

Reasons for omission are only permitted for Disclosure 3-3 Management of material topics in GRI 3.

500
501
502
503

If the organization cannot comply with Disclosure 3-3 or with a requirement in Disclosure 3-3, theorganization is required to specify this in the GRI content index, and to provide a reason for omission
and an explanation. See Requirement 6 in this Standard for more information on reasons foromission.

504
505

Requirement 5: Report disclosures from the GRI Topic Standards
for each material topic

506

The organization shall:

507

a. report disclosures from the GRI Topic Standards for each material topic;

508

b. for each material topic covered in the applicable GRI Sector Standard(s), either:

509
510

i.

report the disclosures from the GRI Topic Standards listed for that topic in the
Sector Standard(s), or;

511
512

ii.

provide the ‘not applicable’ reason for omission and the required explanation in the
GRI content index.

513

Guidance

514

Guidance to 5-a

515
516
517
518

For each material topic, the organization needs to identify disclosures from the GRI Topic Standards
to report. The organization is required to report only those disclosures that are relevant to its impacts
in relation to a material topic. The organization is not required to report disclosures that are not
relevant.

519
520
521

There is no requirement for a minimum number of disclosures to report from the Topic Standards. The
number of disclosures that the organization reports is based on the organization’s assessment of
which disclosures are relevant to its impacts in relation to a material topic.

522
523
524
525
526
527
528
529
530

The organization may need to use more than one Topic Standard to report on a material topic. In
addition, not all disclosures in a Topic Standard may be relevant for the organization to report. For
example, an organization identifies pay equality as a material topic. The organization determines thatthe following disclosures are relevant to report on the topic: Disclosure 202-1 Ratios of standard entry
level wage by gender compared to local minimum wage in GRI 202: Market Presence 2016, andDisclosure 405-2 Ratio of basic salary and remuneration of women to men in GRI 405: Diversity andEqual Opportunity 2016. The organization is not required to report other disclosures from theseStandards (e.g., Disclosure 202-2 Proportion of senior management hired from the local community in
GRI 202), as these disclosures do not address the topic of pay equality.

531
532
533

When a material topic is covered in the applicable GRI Sector Standards, the organization uses the
Sector Standards to identify disclosures to report. See Requirement 5-b in this Standard for more
information.

534
535
536
537
538

Reasons for omission are permitted for all disclosures from the Topic Standards. If the organization
cannot comply with a disclosure or with a requirement in a disclosure, the organization is required to
specify in the GRI content index the disclosure or the requirement it cannot comply with, and toprovide a reason for omission and an explanation. See Requirement 6 in this Standard for more
information on reasons for omission.

539
540
541

The organization should provide sufficient information about its impacts in relation to each material
topic, so that information users can make informed assessments and decisions about theorganization. If the disclosures from the Topic Standards do not provide sufficient information about

Page 18 of 115

542
543
544

the organization’s impacts, then the organization should report additional disclosures. These can
include the additional sector disclosures recommended in the GRI Sector Standards, disclosures fromother sources, or disclosures developed by the organization itself.

545
546
547

Disclosures that the organization reports from other sources, or that are developed by theorganization itself, should have the same rigor as disclosures from the GRI Standards, and theyshould align with expectations set out in authoritative intergovernmental instruments.

548

Reporting on material topics not covered in the GRI Topic Standards

549
550
551

When the organization’s material topic is not covered by the disclosures in the GRI Topic Standards,
the organization is required to report how it manages the material topic, using Disclosure 3-3 in GRI 3:
Material Topics 2021. See Requirement 4-c in this Standard for more information.

552
553
554

In addition to reporting Disclosure 3-3, the organization should report other disclosures for that topic.
These can include the additional sector disclosures recommended in the GRI Sector Standards,
disclosures from other sources, or disclosures developed by the organization itself.

555
556
557
558

For example, an organization identifies freedom of speech as a material topic. As there is no Topic
Standard that covers this topic, the organization should report disclosures from other sources ordevelop its own disclosures to report on the topic. The organization is still required to report how it
manages the topic of freedom of speech, using Disclosure 3-3 in GRI 3.

559

Guidance to 5-b

560
561
562

The organization is required to comply with Requirement 5-b only if GRI Sector Standards that apply
to its sectors are available. The Sector Standards provide information for organizations about theirlikely material topics.

563
564

The organization is required to review each topic described in the applicable Sector Standards anddetermine whether it is a material topic for the organization.

565
566
567
568
569
570
571
572
573

If the organization determines a topic in an applicable Sector Standard to be material, the Sector
Standard helps the organization identify disclosures to report information about its impacts in relation
to that topic. For each likely material topic, the Sector Standards list disclosures from the GRI Topic
Standards for organizations to report. If any of the Topic Standards disclosures listed in the Sector
Standards are not relevant to the organization’s impacts, the organization is not required to reportthese. However, the organization is required to list these disclosures in the GRI content index andprovide ‘not applicable’ as the reason for omission for not reporting the disclosures. The organizationis also required to explain in brief why the disclosures are not relevant to its impacts in relation to thematerial topic. See Requirement 6 in this Standard for more information on reasons for omission.

574
575
576

Note that when reporting the Topic Standards disclosures listed in the Sector Standards, theorganization can still use any of the four reasons for omission included in Table 2 of this Standard if itcannot comply with the disclosure or with a requirement in the disclosure.

577
578
579
580

Besides the disclosures from the Topic Standards, the Sector Standards may list additional sector
disclosures for organizations to report. Reporting these additional sector disclosures is arecommendation. The organization is not required to provide a reason for omission for the additional
sector disclosures it does not report.

Page 19 of 115

582

Requirement 6: Provide reasons for omission for disclosures andrequirements that the organization cannot comply with

583
584
585

a. If the organization cannot comply with a disclosure or with a requirement in a disclosure
for which reasons for omission are permitted, the organization shall in the GRI content
index:

581

586

i.

specify the disclosure or the requirement it cannot comply with;

587
588

ii.

provide one of the four reasons for omission included in Table 2 and the required
explanation for that reason.

589

Table 2. Permitted reasons for omission and required explanations
Reason for omission

Required explanation

Not applicable

Explain why the disclosure or the requirement is considered
not applicable.

Legal prohibitions

Describe the specific legal prohibitions.

Confidentiality constraints

Describe the specific confidentiality constraints.

Information unavailable /incomplete

Specify which information is unavailable or incomplete. Whenthe information is incomplete, specify which part is missing(e.g., specify the entities for which the information is missing).
Explain why the required information is unavailable orincomplete.
Describe the steps being taken, and the expected time frame,
to obtain the information.

590

Guidance591

Reasons for omission are permitted for all disclosures from the GRI Standards except for:592•

Disclosure 2-1 Organizational details

593•

Disclosure 2-2 Entities included in the organization’s sustainability reporting

594•

Disclosure 2-3 Reporting period, frequency and contact point

595•

Disclosure 2-4 Restatements of information

596•

Disclosure 2-5 External assurance

597•

Disclosure 3-1 Process to determine material topics

598•

Disclosure 3-2 List of material topics

599
600
601
602
603
604
605
606
607

The organization is only permitted to provide one of the four reasons for omission included in Table 2of this Standard:•

Not applicable – The organization provides ‘not applicable’ as the reason for omission in thefollowing situations:-

When a disclosure or a requirement in a disclosure does not apply to the organization
based on its characteristics (e.g., size, type). For example, 2-15-b-iii in GRI 2: General
Disclosures 2021 requires the organization to report whether conflicts of interest relating
to existence of controlling shareholders are disclosed to stakeholders. This requirement
does not apply to organizations that do not have shareholders (e.g., foundations).

Page 20 of 115

608
609

In such cases, the organization is required to explain why the disclosure or therequirement does not apply to the organization.

610
611
612
613
614
615
616

However, there may be cases where a disclosure or a requirement in a disclosure applies
to the organization, but the organization does not have in place the item specified in thedisclosure or in the requirement (e.g., committee, policy, practice, process). For example,
2-23-b in GRI 2 requires the organization to describe its policy commitment to respecthuman rights. This expectation applies to every organization. All organizations are
expected to have a policy commitment to respect human rights, but not everyorganization may have developed such a policy commitment yet.

617
618
619
620
621
622
623

If the organization cannot report the required information about an item specified in adisclosure because the item (e.g., committee, policy, practice, process) does not exist, it
can comply with the requirement by reporting this to be the case. It does not need toprovide the ‘not applicable’ reason for omission. In such cases, 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.
-

624
625
626
627
628

When a disclosure from the GRI Topic Standards that is listed in the applicable GRISector Standards is not relevant to the organization’s impacts in relation to a material
topic.
In such cases, the organization is required to explain why the disclosure is not relevant to
its impacts in relation to the material topic.

629
630

•

Legal prohibitions – The organization provides ‘legal prohibitions’ as the reason for omission
when the law forbids collecting the required information or reporting it publicly.

631
632
633
634

•

Confidentiality constraints – There may be cases where the law does not forbid collecting
or reporting the required information, but the organization considers the information
confidential and cannot report it publicly. In such cases, the organization provides‘confidentiality constraints’ as the reason for omission.

635
636
637
638
639
640
641

•

Information unavailable / incomplete – There may be cases where the organization has theitem specified in a disclosure or in a requirement in a disclosure, but the information about theitem is unavailable or incomplete. In such cases, the organization provides ‘information
unavailable / incomplete’ as the reason for omission. For example, information is unavailable
for Disclosure 305-3 in GRI 305: Emissions 2016 when the organization has other indirect(Scope 3) greenhouse gas (GHG) emissions, but it has not collected data on its other indirect(Scope 3) GHG emissions yet.

642
643
644
645
646
647

When the organization cannot report part of the required information it means the information
is incomplete. When the reported information does not cover the complete scope of
information required by a disclosure (e.g., the information is missing for certain entities, sites,
geographic locations), the organization is required to provide ‘information unavailable /incomplete’ as the reason for omission, and to specify the entities, sites, geographic locations,etc., for which the required information is missing and cannot be reported.

648
649
650

The required information, or part of the required information, can be unavailable when, forexample, it cannot be obtained or is not of adequate quality to report. This may be the casewhen the information is collected from another organization, such as a supplier.

651
652
653
654
655
656

The reasons ‘confidentiality constraints’ and ‘information unavailable / incomplete’ should only be
used in exceptional cases. Using ‘confidentiality constraints’ and ‘information unavailable / incomplete’frequently as reasons for omitting information reduces the credibility and usefulness of theorganization’s sustainability reporting. It does not align with the aim of reporting in accordance with
the GRI Standards, which is to provide a comprehensive picture of the organization’s most significant
impacts.

657
658

The organization is not allowed to use other reasons for omission than those included in Table 2 ofthis Standard.

659
660

The organization is required to report reasons for omission in the GRI content index. See
Requirement 7 in this Standard for more information on the content index.

Page 21 of 115

661

Requirement 7: Publish a GRI content index

662

The organization shall:663

a. publish a GRI content index that includes:

664

i.

the title: GRI content index;

665

ii.

the statement of use;

666

iii.

the title of GRI 1 used;

667

iv.

the title(s) of the GRI Sector Standard(s) that apply to the organization’s sector(s);

668

v.

a list of the organization’s material topics;

669
670

vi.

a list of the topics in the applicable GRI Sector Standard(s) determined as notmaterial and an explanation for why they are not material;

671

vii.

a list of the reported disclosures, including the disclosure titles;

672
673

viii.

the titles of the GRI Standards and other sources that the reported disclosurescome from;

674
675
676

ix.

when the organization does not report GRI Topic Standard disclosures for amaterial topic from the applicable GRI Sector Standard(s), a list of the disclosuresand the required reason for omission;

677
678

x.

the GRI Sector Standard reference numbers for the disclosures from the applicable
Sector Standard(s);

679

xi.

the location where the information reported for each disclosure can be found;

680

xii.

any reasons for omission used;

681
682

b. if it publishes a standalone sustainability report and the GRI content index is not includedin the report itself, provide a link or reference to the GRI content index in the report.

683

Guidance

684
685
686
687
688
689

The information reported using the GRI Standards can be published or made accessible in a range offormats (e.g., electronic, paper-based) across one or more locations (e.g., a standalone sustainability
report, web pages, an annual report). The GRI content index provides an overview of theorganization’s reported information, shows where the reported information can be found, and helps
information users access this information. The content index also shows which GRI Standards anddisclosures the organization has used.

690
691
692
693

Appendix 1 of this Standard provides guidance on how to prepare the GRI content index whenreporting in accordance with the GRI Standards. It includes an example that the organization can use
to prepare the content index. The organization can use a different format for the content index thanthe one provided in Appendix 1, as long as it complies with the requirements for the content index.

694

Requirement 8: Provide a statement of use

695

a. The organization shall include the following statement in its GRI content index:

696
697

[Name of organization] has reported in accordance with the GRI Standards for the period[reporting period start and end dates].

Page 22 of 115

698

Guidance

699
700

To state that the organization has reported in accordance with the GRI Standards, the organizationmust have complied with all nine requirements in this section.

701
702

The organization is required to insert the name of the organization and the start and end dates of its
reporting period in the statement, for example:

703
704

‘ABC Limited has reported in accordance with the GRI Standards for the period from 1 January 2022
to 31 December 2022.’

705
706
707

The organization is required to report whether the highest governance body is responsible forreviewing and approving the reported information, including the organization’s material topics, under
Disclosure 2-14 in GRI 2: General Disclosures 2021.

708

Requirement 9: Notify GRI

709
710

a. The organization shall notify GRI of the use of the GRI Standards and the statement of use
by sending an email to reportregistration@globalreporting.org.

711

Guidance712

The organization should include the following information in the email:713•

The legal name of the organization.

714•

The link to the GRI content index.

715•

The link to the report, if publishing a standalone sustainability report.

716•

The statement of use.

717•

A contact person in the organization and their contact details.

718

There is no cost associated with notifying GRI of the use of the GRI Standards.

719

Reporting with reference to the GRI Standards

720
721
722
723
724

An organization can report with reference to the GRI Standards if it cannot comply with all therequirements for reporting in accordance with the GRI Standards. The organization should transition
to reporting in accordance with the GRI Standards in time as it will provide a comprehensive picture of
the organization’s most significant impacts on the economy, environment, and people, including
impacts on their human rights.

725
726
727

The organization can also report with reference to the GRI Standards if it uses selected GRI
Standards, or parts of their content, to report information about specific topics for specific purposes,
for example, to comply with a reporting regulation on climate change.

728
729
730
731

The organization must comply with all three requirements in this section to report with reference to the
GRI Standards. The organization should also apply the reporting principles specified in section 4 ofthis Standard to ensure high-quality reporting. Additionally, the organization should explain how it
manages its impacts for the topics it reports on using Disclosure 3-3 in GRI 3: Material Topics 2021.

732

Overview of requirements for reporting with reference to the GRI Standards
Publish a GRI content index
Provide a statement of use
Notify GRIPage 23 of 115

733

Publish a GRI content index

734

The organization shall:735

a. publish a GRI content index that includes:

736

i.

the title: GRI content index;

737

ii.

the statement of use;

738

iii.

the title of GRI 1 used;

739
740

iv.

a list of the reported disclosures from the GRI Standards, including the disclosure
titles;741v.

the titles of the GRI Standards that the reported disclosures come from;

742

vi.

the location where the information reported for each disclosure can be found;

743
744

b. if it publishes a standalone sustainability report and the GRI content index is not includedin the report itself, provide a link or reference to the GRI content index in the report.

745

Guidance

746
747
748
749
750
751

The information reported using the GRI Standards can be published or made accessible in a range offormats (e.g., electronic, paper-based) across one or more locations (e.g., a standalone sustainability
report, web pages, an annual report). The GRI content index provides an overview of theorganization’s reported information, shows where the reported information can be found, and helps
information users access this information. The content index also shows which GRI Standards anddisclosures the organization has used.

752
753
754
755
756
757
758
759

Appendix 2 of this Standard provides guidance on how to prepare the GRI content index whenreporting with reference to the GRI Standards. It includes an example that the organization can use toprepare the content index. The organization can use a different format for the content index than the
one provided in Appendix 2, as long as it complies with the requirements for the content index. The
organization can also use the content index specified for reporting in accordance with the GRI
Standards in Appendix 1 of this Standard, if suitable. In such a case, the statement of use in Appendix
1, which is for reporting in accordance with the GRI Standards, must be replaced by the statement ofuse for reporting with reference to the GRI Standards.

760

Provide a statement of use

761

a. The organization shall include the following statement in its GRI content index:

762
763

[Name of organization] has reported the information cited in this GRI content index for theperiod [reporting period start and end dates] with reference to the GRI Standards.

764

Guidance765
766

To state that the organization has reported with reference to the GRI Standards, the organizationmust have complied with all three requirements in this section.

767
768

The organization is required to insert the name of the organization and the start and end dates of its
reporting period in the statement, for example:

769
770

‘ABC Limited has reported the information cited in this GRI content index for the period from 1
January 2022 to 31 December 2022 with reference to the GRI Standards.’

Page 24 of 115

771

Notify GRI

772
773

a. The organization shall notify GRI of the use of the GRI Standards and the statement of use
by sending an email to reportregistration@globalreporting.org.

774

Guidance775

The organization should include the following information in the email:776•

The legal name of the organization.

777•

The link to the GRI content index.

778•

The link to the report, if publishing a standalone sustainability report.

779•

The statement of use.

780•

A contact person in the organization and their contact details.

781

There is no cost associated with notifying GRI of the use of the GRI Standards.

Page 25 of 115

782

4. Reporting principles

783
784
785

The reporting principles are fundamental to achieving high-quality sustainability reporting. An
organization is required to apply the reporting principles to be able to claim that it has prepared thereported information in accordance with the GRI Standards (see section 3 in this Standard).

786
787
788
789

The reporting principles guide the organization in ensuring the quality and proper presentation of thereported information. High-quality information allows information users to make informed
assessments and decisions about the organization’s impacts and its contribution to sustainable
development.

790

Each reporting principle consists of a requirement and guidance on how to apply it.

791

Overview of principles

792•

Accuracy

793•

Balance

794•

Clarity795•

Comparability

796•

Completeness

797•

Sustainability context

798•

Timeliness

799•

Verifiability

800

Accuracy

801

Requirement

802
803

a. The organization shall report information that is correct and sufficiently detailed to allow
an assessment of the organization’s impacts.

804

Guidance

805
806
807
808
809
810

The characteristics that determine accuracy vary depending on the nature of the information(qualitative or quantitative) and the intended use of the information. The accuracy of quantitative
information depends on the specific methods used to gather, compile, and analyze data. The
accuracy of qualitative information depends on the level of detail and consistency with available
evidence. Information users require sufficient detail to make assessments about the organization’s
impacts.

811

To apply the Accuracy principle, the organization should:

812
813

•

report qualitative information that is consistent with available evidence and other reported
information;

814•

indicate which data has been measured;

815
816

•

adequately describe data measurements and bases for calculations, and ensure it is possible
to replicate measurements and calculations with similar results;

817
818

•

ensure that the margin of error for data measurements does not inappropriately influence theconclusions or assessments of information users;

819
820

•

indicate which data has been estimated, and explain the underlying assumptions andtechniques used for the estimation as well as any limitations of the estimates.

Page 26 of 115

821

Balance822

Requirement

823
824

a. The organization shall report information in an unbiased way and provide a fair
representation of the organization’s negative and positive impacts.

825

Guidance826

To apply the Balance principle, the organization should:

827
828

•

present information in a way that allows information users to see negative and positive yearon-year trends in impacts;829•

distinguish clearly between facts and the organization’s interpretation of the facts;830•

not omit relevant information concerning its negative impacts;831•

not overemphasize positive news or impacts;

832
833

•

not present information in a way that is likely to inappropriately influence the conclusions orassessments of information users.

834

Clarity835

Requirement

836

a. The organization shall present information in a way that is accessible and understandable.

837

Guidance838

To apply the Clarity principle, the organization should:

839
840

•

take into account specific accessibility needs of information users, associated with abilities,
language, and technology;

841
842

•

present information in a way that users are able to find the information they want without
unreasonable effort, for example, through a table of contents, maps, or links;

843
844

•

present information in a way that it can be understood by users who have reasonableknowledge of the organization and its activities;

845
846

•

avoid abbreviations, technical terms, or other jargon likely to be unfamiliar to users or, if these
are used, include relevant explanations in the appropriate sections or in a glossary;

847
848

•

report information in a concise way and aggregate information where useful without omitting
necessary details;

849
850

•

use graphics and consolidated data tables to make information accessible andunderstandable.

851

Comparability

852

Requirement

853
854
855

a. The organization shall select, compile, and report information in a consistent manner, toenable an analysis of changes in the organization’s impacts over time and an analysis ofthese impacts relative to those of other organizations.

Page 27 of 115

856

Guidance

857
858
859
860

Information reported in a comparable way enables the organization and other information users toassess the organization’s current impacts against its past impacts and its goals and targets. It alsoenables external parties to assess and benchmark the organization’s impacts against impacts of otherorganizations, as part of rating activities, investment decisions, and advocacy programs.

861

To apply the Comparability principle, the organization should:

862
863

•

present information for the current reporting period and at least two previous periods, as wellas any goals and targets that have been set;

864
865

•

use generally accepted international metrics (e.g., kilograms, liters), and standard conversion
factors and protocols, where applicable, for compiling and reporting information;

866
867

•

maintain consistency in the methods used to measure and calculate data and in explaining
the methods and assumptions used;868•

maintain consistency in the manner of presenting the information;

869
870
871

•

report total numbers or absolute data (e.g., metric tons of CO2 equivalent) as well as ratios ornormalized data (e.g., CO2 emissions per unit produced) to enable comparisons, and provide
explanatory notes when using ratios;

872
873
874

•

provide contextual information (e.g., the organization’s size, geographic location) to help
information users understand the factors that contribute to differences between theorganization’s impacts and the impacts of other organizations;

875
876
877
878
879

•

present the current disclosures alongside restatements of historical data to enable
comparisons if there have been changes from the information reported previously. This can
include changes in the length of the reporting period, in the measurement methodologies, inthe definitions used, or in other elements of reporting. The organization is required to reportrestatements of information under Disclosure 2-4 in GRI 2: General Disclosures 2021;

880
881

•

if restatements of historical data are not provided, explain the changes to provide contextual
information for interpreting the current disclosures.

882

Completeness883

Requirement

884
885

a. The organization shall provide sufficient information to enable an assessment of theorganization’s impacts during the reporting period.

886

Guidance887

To apply the Completeness principle, the organization should:

888
889
890
891

•

present activities, events, and impacts for the reporting period in which they occur. This
includes reporting information about activities that have a minimal impact in the short-term,
but a reasonably foreseeable cumulative impact that can become unavoidable or irreversible
in the long-term (e.g., activities that generate bio-accumulative or persistent pollutants);892•

not omit information that is necessary for understanding the organization’s impacts.

893
894
895

If the organization consists of multiple entities (i.e., a parent entity and its subordinate entities), theorganization is required to explain the approach used for consolidating the information under 2-2-c in
GRI 2: General Disclosures 2021.

896
897
898
899
900

If information for a disclosure or a requirement in a disclosure for which reasons for omission are
permitted is unavailable or incomplete, the organization is required to provide a reason for omission.
When information is incomplete, the organization is required to specify which part is missing (e.g.,
specify the entities for which the information is missing). See Requirement 6 in this Standard for more
information.

Page 28 of 115

901

Sustainability context

902

Requirement

903
904

a. The organization shall report information about its impacts in the wider context ofsustainable development.

905

Guidance

906
907
908
909
910
911

Sustainable development has been defined as ‘development which meets the needs of the present
without compromising the ability of future generations to meet their own needs’ [8]. The objective ofsustainability reporting using the GRI Standards is to provide transparency on how an organization
contributes or aims to contribute to sustainable development. For this purpose, the organizationneeds to assess and report information about its impacts in the wider context of sustainable
development.

912

To apply the Sustainability context principle, the organization should:

913
914
915

•

draw on objective information, and authoritative measures on sustainable development toreport information about its impacts (e.g., scientific research or consensus on the limits anddemands placed on environmental resources);

916
917
918
919

•

report information about its impacts in relation to sustainable development goals andconditions (e.g., reporting total greenhouse gas [GHG] emissions as well as reductions in
GHG emissions in relation to the goals set out in the United Nations [UN] Framework
Convention on Climate Change [FCCC] Paris Agreement [4]);

920
921
922
923
924
925

•

report information about its impacts in relation to societal expectations and expectations ofresponsible business conduct set out in authoritative intergovernmental instruments withwhich the organization is expected to comply (e.g., Organisation for Economic Co-operation
and Development [OECD] Guidelines for Multinational Enterprises [3], UN Guiding Principles
on Business and Human Rights [5]) and in other recognized sector-specific, local, regional, or
global instruments;

926
927
928

•

if operating in a range of locations, report information about its impacts in relation toappropriate local contexts (e.g., reporting total water use, as well as water use relative to thesustainable thresholds and the social context of given catchments).

929
930
931
932

Understanding the sustainability context provides the organization with critical information todetermine and report on its material topics (see GRI 3: Material Topics 2021). The GRI Sector
Standards describe the sectors’ context and they can also help the organization in understanding its
sustainability context.

933

Timeliness

934

Requirement

935
936

a. The organization shall report information on a regular schedule and make it available intime for information users to make decisions.

937

Guidance

938
939
940

The usefulness of information is closely tied to whether it is available in time for information users tointegrate it into their decision-making. The Timeliness principle refers to how regularly as well as how
soon after the reporting period the information is published.

941

To apply the Timeliness principle, the organization should:

942
943
944

•

find a balance between the need to make information available in a timely manner andensuring that the information is of high quality and meets the requirements under the otherreporting principles;

Page 29 of 115

945

•

ensure consistency in the length of reporting periods;

946•

indicate the time period covered by the reported information.

947
948

See section 5.1 in this Standard for information on aligning the reporting periods and publishingschedules of sustainability reporting and other types of reporting.

949

Verifiability

950

Requirement

951
952

a. The organization shall gather, record, compile, and analyze information in such a way thatthe information can be examined to establish its quality.

953

Guidance954
955

It is important that the reported information can be examined to establish its veracity and to determine
the extent to which the reporting principles have been applied.

956

To apply the Verifiability principle, the organization should:

957
958
959

•

set up internal controls and organize documentation in such a way that individuals other thanthose preparing the reported information (e.g., internal auditors, external assurance providers)
are able to review them;

960
961
962

•

document the decision-making processes underlying the organization’s sustainability
reporting in a way that allows for the examination of the key decisions and processes, such as
the process of determining material topics;

963
964

•

if the organization designs information systems for its sustainability reporting, design thesesystems in a way that they can be examined as part of an external assurance process;

965
966

•

be able to identify the original sources of the reported information and provide reliable
evidence to support assumptions or calculations;

967
968

•

be able to provide representation from the original sources of the reported information
attesting to the accuracy of the information within acceptable margins of error;

969
970

•

avoid including information that is not substantiated by evidence, unless it is relevant forunderstanding the organization’s impacts;

971
972

•

provide unambiguous explanations of any uncertainties associated with the reported
information.

973
974

See section 5.2 in this Standard for more information on enhancing the credibility of the organization’ssustainability reporting.

Page 30 of 115

975

5. Additional recommendations for976

reporting977
978This section presents recommendations for an organization to align its sustainability reporting withother types of reporting and to enhance the credibility of its sustainability reporting.

979

5.1 Aligning sustainability reporting with other reporting

980
981
982
983
984

An organization should align its sustainability reporting with other statutory and regulatory reporting, inparticular its financial reporting. This means that the organization should report the information for thesame reporting period and for the same group of entities as covered in its financial reporting. The
organization should also publish the information at the same time as its financial reporting, where thisis possible.

985

5.2 Enhancing the credibility of sustainability reporting

986
987
988
989

There are several ways in which an organization can enhance the credibility of its sustainability
reporting. These include the use of internal controls, external assurance, and stakeholder or expert
panels. The organization is not required to apply these methods when reporting in accordance with
the GRI Standards but is encouraged to do so.

990Internal controls

991
992
993
994

The organization should set up internal controls to strengthen the integrity and credibility of its
sustainability reporting. Internal controls are processes designed and implemented by theorganization, generally its management, to provide reasonable assurance regarding the achievementof its objectives.

995
996
997

Internal controls can be implemented in day-to-day operations and through compliance functions. The
organization can also establish and maintain an internal audit function as part of its processes for risk
management to further improve the credibility of its sustainability reporting.

998
999
1000
1001
1002
1003
1004
1005

In some jurisdictions, corporate governance codes require the highest governance body to inquire
and, if it is satisfied, to confirm the adequacy of an organization’s internal controls in the annual
report. This confirmation may only relate to the adequacy of the internal controls for financial
reporting. It may not provide information about whether the same internal controls are also adequate
to assess the credibility of the organization’s sustainability reporting. If the organization relies oninternal controls set up for financial reporting, it should assess the relevance of these controls for its
sustainability reporting. In cases where these controls are inadequate, the organization should identify
and use additional internal controls to assess the credibility of its sustainability reporting.

1006

External assurance

1007
1008
1009
1010
1011

In addition to internal controls, the organization should seek external assurance for its sustainability
reporting. Disclosure 2-5 in GRI 2: General Disclosures 2021 requires the organization to describe its
policy and practice for seeking external assurance for its sustainability reporting. If the sustainability
reporting has been externally assured, the organization is also required to describe what has beenexternally assured and on what basis.

1012
1013
1014
1015
1016
1017

External assurance comprises activities carried out by assurance providers to assess the quality andcredibility of the qualitative and quantitative information reported by the organization. External
assurance can also be used to assess the systems or processes the organization uses to prepare theinformation (e.g., the process of determining material topics). External assurance is different from
activities that are used to assess or validate the performance of the organization, such as complianceassessments or the issuing of performance certifications.

Page 31 of 115

1018
1019
1020
1021
1022

External assurance results in published assurance reports or conclusions that can be used to verify
that the information has been prepared in accordance with reporting standards. It can also be used toreduce risk in data quality and increase trust in the reported information. This, in turn, helps
information users as well as the organization rely on the reported information for their decisionmaking.

1023
1024

External assurance should be conducted by competent assurance providers with appropriate
experience and qualifications. Assurance providers should be:

1025
1026
1027

•

independent from the organization and therefore able to reach impartial and objective
conclusions about the organization’s reporting and to publish these conclusions in a reportthat is publicly available;

1028

•

demonstrably competent in the subject matter and assurance practices;

1029

•

competent in applying quality control procedures to the assurance engagement;

1030
1031
1032

•

able to conduct the engagement in a manner that is systematic, documented, evidencebased, and characterized by defined procedures in line with professional standards forassurance;

1033
1034
1035

•

able to consider the selection of the information reported as well as its accuracy, and toassess whether the reporting provides a comprehensive picture of the organization’s mostsignificant impacts and how it manages these impacts;

1036
1037

•

able to assess the extent to which the organization has applied the GRI Standards in thecourse of formulating opinions or reaching conclusions.

1038

Stakeholder or expert panels

1039
1040

The organization can also convene a stakeholder or expert panel to seek views on its approach tosustainability reporting or for advice on the information to be reported.

Page 32 of 115

A1

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance

A1

GRI content index

A2

Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)­OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard][Topic][Explanation][Topic][Explanation]

A2

GRI 1: Foundation 2021 - Appendix 1

Guidance

This Appendix provides guidance on how to prepare the GRI content index when reporting in accordance with the GRI
Standards. It includes an example that the organization can use to prepare the content index. The organization can use
a different format for the content index than the one provided here, as long as it complies with the requirements for thecontent index specified in Requirement 7 in this Standard.

A3
A4
A5
A6
A7

The organization can include additional information in the content index, beyond what is required by the GRI Standards.
For example, the organization can show how the disclosures it has reported using the GRI Standards are related tothose required by other reporting standards or frameworks.

A8
A9
A10

The organization should make sure that such additions do not compromise the readability of the content index. This canbe done by providing any additional information in separate columns or rows that are included at the end of the content
index, after all the required information has been specified.

A11
A12
A13

The organization should not report the information required by the disclosures directly in the content index. Exceptions
can be made if the information is brief and easier to find in the content index than in other locations (e.g., informationon the reporting period may be easier to find when stated directly in the content index); or to report that an item (e.g.,committee, policy, practice, process) specified in a disclosure does not exist. Detailed reporting in the content index
should be avoided.

A14
A15
A16
A17
A18

1

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

Statement of use
The organization is required to include in the GRI content index the statement of use forreporting in accordance with the GRI Standards, as specified in Requirement 7-a-ii in thisStandard. See Requirement 8 in this Standard for more information on the statement of
use.

A19
A20
A21
A22
A23

GRI 1 used
The organization is required to include in the GRI content index the title of GRI 1 it has
used, as specified in Requirement 7-a-iii in this Standard. The title of GRI 1 includes thenumber, name, and publication year (e.g., GRI 1: Foundation 2021).

A24
A25
A26
A27

GRI 1 does not contain disclosures, but it does specify the requirements for reportingin accordance with the GRI Standards. The GRI Standards are regularly updated, anda newer version of GRI 1 may have different requirements for reporting in accordancewith the GRI Standards than its previous version. Indicating which version of GRI 1 theorganization has used helps clarify which requirements it must comply with.

A28
A29
A30
A31
A32

Applicable GRI Sector Standard(s)The organization is required to include in the GRI content index the titles of the GRI Sector
Standards that apply to its sectors, as specified in Requirement 7-a-iv in this Standard.
The title of a GRI Sector Standard includes the number, name, and publication year (e.g.,
GRI 11: Oil and Gas Sector 2021).

A33
A34
A35
A36
A37

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard][Topic][Explanation][Topic][Explanation]

A3

GRI 1: Foundation 2021 - Appendix 1

1

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICS

Titles of the GRI Standards and other sources of reported disclosures
The organization is required to include in the GRI content index the titles of the GRI
Universal Standards, GRI Sector Standards, and GRI Topic Standards it has used toreport disclosures, as specified in Requirement 7-a-viii in this Standard. These include:• GRI 2: General Disclosures 2021;• GRI 3: Material Topics 2021;• the Topic Standards the organization has used for reporting on its material topics;• the Sector Standards the organization has used to report additional sector disclosureslisted for its material topics.

A38
A39
A40
A41
A42
A43
A44
A45
A46

The title of a GRI Standard includes the number, name, and publication year (e.g., GRI
303: Water and Effluents 2018).

A47
A48

The publication year indicates which version of a GRI Standard the organization has used.
The GRI Standards are regularly updated, and a newer version of a GRI Standard may
have different disclosures than its previous version. The publication year of the Standard
does not refer to the reporting period covered by the reported information or to the yearthat the reported information is published.

A49
A50
A51
A52
A53

If the organization reports disclosures from other sources, the organization is required toinclude in the content index the titles of the sources it has used.

A54
A55

Disclosures
The organization is required to list in the GRI content index all the disclosures it hasreported, as specified in Requirement 7-a-vii in this Standard. These include thedisclosures from GRI 2: General Disclosures 2021 and GRI 3: Material Topics 2021, andthe disclosures it has reported for each material topic.

A56
A57
A58
A59
A60

For each material topic the organization is required to list the disclosures it has reported
from the GRI Topic Standards and GRI Sector Standards, as well as the disclosures it hasreported from other sources. The organization should organize these disclosures by eachmaterial topic. See Requirement 5-a and Requirement 5-b-i in this Standard for more
information on reporting disclosures for each material topic.

A61
A62
A63
A64
A65

Besides the disclosures from the Topic Standards, the Sector Standards may list
additional sector disclosures for organizations to report. Reporting these additional sector
disclosures is a recommendation. If the organization reports any of these additional sector
disclosures for its material topics, it is required to list them in the content index.

A66
A67
A68
A69

The organization is required to include the disclosure titles in the content index. The titleof a disclosure includes the number and name (e.g., 2-6 Activities, value chain and otherbusiness relationships).

A70
A71
A72

For disclosures from other sources, if there is no disclosure title available, the organization
can list any other information that helps identify the disclosure.

A73
A74

GRI Topic Standards disclosures listed in the applicable GRI Sector Standards thatare not reported
For each topic in the applicable GRI Sector Standards determined as material, theorganization is required to include in the GRI content index any GRI Topic Standards
disclosures listed for that topic that the organization does not report, as specified in
Requirement 7-a-ix in this Standard.

A75
A76
A77
A78
A79
A80

There can be cases where a Topic Standard disclosure listed in the Sector Standard is not
relevant to the organization’s impacts in relation to the material topic. In such cases, theorganization is required to provide the ‘not applicable’ reason for omission, and to briefly
explain why the disclosure is not relevant. See Requirement 5-b in this Standard for more
information on reporting on material topics covered in the Sector Standards.

A81
A82
A83
A84
A85

EXPLANATION[Title of GRI Sector Standard]

1[Topic][Explanation][Topic][Explanation]

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard][Topic][Explanation][Topic][Explanation]

A4

GRI 1: Foundation 2021 - Appendix 1

1

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

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“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021
[Title of source]“

3-3 Management ofmaterial topics

Location
For each disclosure that it has reported, the organization is required to include in the
GRI content index the location (i.e., the specific page numbers or links) in, for example,
a report, document, website where the information can be found, as specified in
Requirement 7-a-xi in this Standard. If the information reported for a disclosure is spread
across multiple pages or web pages, the organization is required to specify all page
numbers and links across which the information is distributed.

A86
A87
A88
A89
A90
A91
A92

If the organization is required to report information that it has previously reported, and theinformation has not changed during the reporting period (e.g., the organization is required
to report information about a policy or process that has not changed since the previous
reporting period), the organization can republish this information or provide a reference tothe previously reported information in the content index.

A93
A94
A95
A96
A97

Omissions
The organization is required to include in the GRI content index the reasons for omission
it has used for each disclosure or requirement it cannot comply with, as specified in
Requirement 7-a-xii in this Standard.

A98
A99
A100
A101

If the organization cannot comply with a disclosure or with a requirement in a disclosure
for which reasons for omission are permitted, the organization is required to specify thedisclosure or the requirement it cannot comply with in the content index. It is also required
to provide one of the permitted reasons for omission and the required explanation for thatreason. The four permitted reasons for omission are: not applicable, legal prohibitions,confidentiality constraints, and information unavailable / incomplete. See Requirement 6
in this Standard for more information on reasons for omission.

A102
A103
A104
A105
A106
A107
A108

GRI Sector Standard reference numbers
When listing the GRI disclosures and additional sector disclosures from the applicable
GRI Sector Standards in the GRI content index, the organization is required to include
the GRI Sector Standard reference numbers, as specified in Requirement 7-a-x in thisStandard. The GRI Sector Standard reference number refers to the unique identifier foreach disclosure listed in a Sector Standard (e.g., S11.1.1). This identifier helps information
users assess which of the disclosures listed in the Sector Standards are included in theorganization’s reporting.

A109
A110
A111
A112
A113
A114
A115
A116

Material topics
The organization is required to list its material topics in the GRI content index, as specified
in Requirement 7-a-v in this Standard.

A117
A118
A119

The list of material topics included in the content index is the same as the list of material
topics reported under 3-2-a in GRI 3: Material Topics 2021.

A120
A121

[Disclosure title]

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard]

1[Topic][Explanation][Topic][Explanation]

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)GRI STANDARD/OTHER SOURCE[Titles of the applicable GRI Sector Standards]

DISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021
[Title of source]“

3-3 Management ofmaterial topics[Disclosure title]

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard]

1[Topic][Explanation][Topic][Explanation]

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard]

1[Topic][Explanation][Topic][Explanation]

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)GRI STANDARD/OTHER SOURCE[Titles of the applicable GRI Sector Standards]

DISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard][Topic][Explanation][Topic][Explanation]

A5

GRI 1: Foundation 2021 - Appendix 1

1

GRI 1: Foundation 2021 - Appendix 1

Appendix 1. GRI content index in accordance
GRI content index
Statement of use[Name of organization] has reported in accordance with the GRI Standards forthe period [reporting period start and end dates].

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)[Titles of the applicable GRI Sector Standards]

GRI STANDARD/OTHER SOURCEDISCLOSURE

LOCATIONOMISSIONREQUIREMENT(S)OMITTEDREASONEXPLANATIONGRISECTOR
STANDARD
REF. NO.

General disclosures
GRI 2: General
Disclosures 2021

2-1 Organizational details
2-2 Entities includedin the organization’ssustainability reporting

A gray cell indicates something that does not apply.
This only relates to the ‘Omission’ and ‘GRI Sector
Standard ref. no.’ columns.

2-3 Reporting period,
frequency and contact
point
2-4 Restatements of
information
2-5 External assurance
2-6 Activities, value
chain and other business
relationships
“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

“

2-30 Collective
bargaining agreements

Material topics
GRI 3: Material
Topics 2021

3-1 Process to determinematerial topics
3-2 List of material topics[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

[Material topic]
GRI 3: Material
Topics 2021

3-3 Management ofmaterial topics[Title of source][Disclosure title]

“

“

“

“

Topics in the applicable GRI Sector Standards determined as not material
TOPICSEXPLANATION[Title of GRI Sector Standard][Topic][Explanation][Topic][Explanation]

Topics in the applicable GRI Sector Standards determined as not material
The organization is required to list in the GRI content index any topics from the applicable
GRI Sector Standards that it has determined as not material and explain why they are notmaterial, as specified in Requirement 7-a-vi in this Standard. See Requirement 3-b inthis Standard for more information on using the Sector Standards to determine material
topics.

A122
A123
A124
A125
A126
A127

A6

GRI 1: Foundation 2021 - Appendix 2

Appendix 2. GRI content index with reference

A128

GRI content index

A129

Statement of use[Name of organization] has reported the information cited in this GRI content
index for the period [reporting period start and end dates] with reference to
the GRI Standards.

GRI 1 used

GRI 1: Foundation 2021

GRI STANDARDDISCLOSURE[Title of GRI Standard][Disclosure title][Title of GRI Standard][Disclosure title]

LOCATION

Guidance

This Appendix provides guidance on how to prepare the GRI content index when reporting with reference to the GRI
Standards. It includes an example that the organization can use to prepare the content index. The organization can use
a different format for the content index than the one provided here, as long as it complies with the requirements for thecontent index specified in ‘Reporting with reference to the GRI Standards’ at the end of section 3 of this Standard.
The organization can also use the content index specified for reporting in accordance with the GRI Standards inAppendix 1, if suitable. In such a case, the statement of use in Appendix 1, which is for reporting in accordance with the
GRI Standards, must be replaced by the statement of use for reporting with reference to the GRI Standards.

A130
A131
A132
A133
A134
A135
A136
A137

The organization can include additional information in the content index, beyond what is required by the GRI Standards.
For example, the organization can show how the disclosures it has reported using the GRI Standards are related tothose required by other reporting standards or frameworks.

A138
A139
A140

The organization should make sure that such additions do not compromise the readability of the content index. This canbe done by providing any additional information in separate columns or rows that are included at the end of the content
index, after all the required information has been specified.

A141
A142
A143

The organization should not report the information required by the disclosures directly in the content index. Exceptions
can be made if the information is brief and easier to find in the content index than in other locations (e.g., informationon the reporting period may be easier to find when stated directly in the content index). Detailed reporting in the content
index should be avoided.

A144
A145
A146
A147

A7

GRI 1: Foundation 2021 - Appendix 2

6

GRI 1: Foundation 2021 - Appendix 2

Appendix 2. GRI content index with reference
GRI content index
Statement of use[Name of organization] has reported the information cited in this GRI content
index for the period [reporting period start and end dates] with reference to
the GRI Standards.

GRI 1 used

GRI 1: Foundation 2021

GRI STANDARDDISCLOSURE[Title of GRI Standard][Disclosure title][Title of GRI Standard][Disclosure title]

LOCATION

Guidance

This Appendix provides guidance on how to prepare the GRI content index when reporting with reference to the GRI
Standards. It includes an example that the organization can use to prepare the content index. The organization can use
a different format for the content index than the one provided here, as long as it complies with the requirements for thecontent index specified in ‘Reporting with reference to the GRI Standards’ at the end of section 3 of this Standard.
The organization can also use the content index specified for reporting in accordance with the GRI Standards inAppendix 1, if suitable. In such a case, the statement of use in Appendix 1, which is for reporting in accordance with the
GRI Standards, must be replaced by the statement of use for reporting with reference to the GRI Standards.
The organization can include additional information in the content index, beyond what is required by the GRI Standards.
For example, the organization can show how the disclosures it has reported using the GRI Standards are related tothose required by other reporting standards or frameworks.
The organization should make sure that such additions do not compromise the readability of the content index. This canbe done by providing any additional information in separate columns or rows that are included at the end of the content
index, after all the required information has been specified.
The organization should not report the information required by the disclosures directly in the content index. Exceptions
can be made if the information is brief and easier to find in the content index than in other locations (e.g., informationon the reporting period may be easier to find when stated directly in the content index). Detailed reporting in the content
index should be avoided.

6

A148
A149
A150
A151
A152
A153
A154

GRI 1 used
The organization is required to include in the GRI content index the title of GRI 1 it has
used, as specified in Requirement a-iii in ‘Reporting with reference to the GRI Standards’
at the end of section 3 of this Standard. The title of GRI 1 includes the number, name, andpublication year (e.g., GRI 1: Foundation 2021).

A155
A156
A157
A158
A159

GRI 1 does not contain disclosures, but it does specify the requirements for reporting withreference to the GRI Standards. The GRI Standards are regularly updated, and a newer
version of GRI 1 may have different requirements for reporting with reference to the GRI
Standards than its previous version. Indicating which version of GRI 1 the organization
has used helps clarify which requirements it must comply with.

A160
A161
A162
A163
A164

Titles of the GRI Standards of reported disclosures
The organization is required to include in the GRI content index the titles of all the GRI
Standards it has used to report disclosures, as specified in Requirement a-v in ‘Reportingwith reference to the GRI Standards’ at the end of section 3 of this Standard. These can
include GRI 2: General Disclosures 2021, GRI 3: Material Topics 2021, the GRI Sector
Standards, and the GRI Topic Standards.

A165
A166
A167
A168
A169
A170

The title of a GRI Standard includes the number, name, and publication year (e.g., GRI
303: Water and Effluents 2018).

A171
A172

The publication year indicates which version of a GRI Standard the organization has used.
The GRI Standards are regularly updated, and a newer version of a GRI Standard may
have different disclosures than its previous version. The publication year of the Standard
does not refer to the reporting period covered by the reported information or to the yearthat the reported information is published.

A173
A174
A175
A176
A177

Disclosures
The organization is required to list in the GRI content index all the disclosures it hasreported from the GRI Standards, as specified in Requirement a-iv in ‘Reporting withreference to the GRI Standards’ at the end of section 3 of this Standard.

A178
A179
A180
A181

The organization is required to include the disclosure titles in the content index. The title ofa disclosure includes the number and name (e.g., 303-3 Water withdrawal).

A182
A183

Location
For each disclosure that it has reported, the organization is required to include in the
GRI content index the location (i.e., the specific page numbers or links) in, for example,
a report, document, website where the information can be found, as specified in
Requirement a-vi in ‘Reporting with reference to the GRI Standards’ at the end of section
3 of this Standard. If the information reported for a disclosure is spread across multiple
pages or web pages, the organization is required to specify all page numbers and links
across which the information is distributed.

A184
A185
A186
A187
A188
A189
A190
A191

GRI 1: Foundation 2021 - Appendix 2

Appendix 2. GRI content index with reference
GRI content index
Statement of use[Name of organization] has reported the information cited in this GRI content
index for the period [reporting period start and end dates] with reference to
the GRI Standards.

GRI 1 used

GRI 1: Foundation 2021

GRI STANDARDDISCLOSURE[Title of GRI Standard][Disclosure title][Title of GRI Standard][Disclosure title]

LOCATION

Guidance

This Appendix provides guidance on how to prepare the GRI content index when reporting with reference to the GRI
Standards. It includes an example that the organization can use to prepare the content index. The organization can use
a different format for the content index than the one provided here, as long as it complies with the requirements for thecontent index specified in ‘Reporting with reference to the GRI Standards’ at the end of section 3 of this Standard.
The organization can also use the content index specified for reporting in accordance with the GRI Standards inAppendix 1, if suitable. In such a case, the statement of use in Appendix 1, which is for reporting in accordance with the
GRI Standards, must be replaced by the statement of use for reporting with reference to the GRI Standards.
The organization can include additional information in the content index, beyond what is required by the GRI Standards.
For example, the organization can show how the disclosures it has reported using the GRI Standards are related tothose required by other reporting standards or frameworks.
The organization should make sure that such additions do not compromise the readability of the content index. This canbe done by providing any additional information in separate columns or rows that are included at the end of the content
index, after all the required information has been specified.
The organization should not report the information required by the disclosures directly in the content index. Exceptions
can be made if the information is brief and easier to find in the content index than in other locations (e.g., informationon the reporting period may be easier to find when stated directly in the content index). Detailed reporting in the content
index should be avoided.

6

Statement of use
The organization is required to include in the GRI content index the statement of use
for reporting with reference to the GRI Standards, as specified in Requirement a-ii in‘Reporting with reference to the GRI Standards’ at the end of section 3 of this Standard.
See the requirement to provide a statement of use in ‘Reporting with reference to
the GRI Standards’ at the end of section 3 of this Standard for more information on thestatement of use.

GRI 1: Foundation 2021 - Appendix 2

Appendix 2. GRI content index with reference
GRI content index
Statement of use[Name of organization] has reported the information cited in this GRI content
index for the period [reporting period start and end dates] with reference to
the GRI Standards.

GRI 1 used

GRI 1: Foundation 2021

GRI STANDARDDISCLOSURE[Title of GRI Standard][Disclosure title][Title of GRI Standard][Disclosure title]

LOCATION

Guidance

This Appendix provides guidance on how to prepare the GRI content index when reporting with reference to the GRI
Standards. It includes an example that the organization can use to prepare the content index. The organization can use
a different format for the content index than the one provided here, as long as it complies with the requirements for thecontent index specified in ‘Reporting with reference to the GRI Standards’ at the end of section 3 of this Standard.
The organization can also use the content index specified for reporting in accordance with the GRI Standards inAppendix 1, if suitable. In such a case, the statement of use in Appendix 1, which is for reporting in accordance with the
GRI Standards, must be replaced by the statement of use for reporting with reference to the GRI Standards.
The organization can include additional information in the content index, beyond what is required by the GRI Standards.
For example, the organization can show how the disclosures it has reported using the GRI Standards are related tothose required by other reporting standards or frameworks.
The organization should make sure that such additions do not compromise the readability of the content index. This canbe done by providing any additional information in separate columns or rows that are included at the end of the content
index, after all the required information has been specified.
The organization should not report the information required by the disclosures directly in the content index. Exceptions
can be made if the information is brief and easier to find in the content index than in other locations (e.g., informationon the reporting period may be easier to find when stated directly in the content index). Detailed reporting in the content
index should be avoided.

6

GRI 1: Foundation 2021 - Appendix 2

Appendix 2. GRI content index with reference
GRI content index
Statement of use[Name of organization] has reported the information cited in this GRI content
index for the period [reporting period start and end dates] with reference to
the GRI Standards.

GRI 1 used

GRI 1: Foundation 2021

GRI STANDARDDISCLOSURE[Title of GRI Standard][Disclosure title][Title of GRI Standard][Disclosure title]

LOCATION

Guidance

This Appendix provides guidance on how to prepare the GRI content index when reporting with reference to the GRI
Standards. It includes an example that the organization can use to prepare the content index. The organization can use
a different format for the content index than the one provided here, as long as it complies with the requirements for thecontent index specified in ‘Reporting with reference to the GRI Standards’ at the end of section 3 of this Standard.
The organization can also use the content index specified for reporting in accordance with the GRI Standards inAppendix 1, if suitable. In such a case, the statement of use in Appendix 1, which is for reporting in accordance with the
GRI Standards, must be replaced by the statement of use for reporting with reference to the GRI Standards.
The organization can include additional information in the content index, beyond what is required by the GRI Standards.
For example, the organization can show how the disclosures it has reported using the GRI Standards are related tothose required by other reporting standards or frameworks.
The organization should make sure that such additions do not compromise the readability of the content index. This canbe done by providing any additional information in separate columns or rows that are included at the end of the content
index, after all the required information has been specified.
The organization should not report the information required by the disclosures directly in the content index. Exceptions
can be made if the information is brief and easier to find in the content index than in other locations (e.g., informationon the reporting period may be easier to find when stated directly in the content index). Detailed reporting in the content
index should be avoided.

1041

Glossary

1042
1043

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

1044
1045
1046

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.

1047

business partner

1048
1049

entity with which the organization has some form of direct and formal engagement for the purpose of
meeting its business objectives

1050

Source: Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015; modified

1051
1052

Examples: affiliates, business-to-business customers, clients, first-tier suppliers, franchisees, joint
venture partners, investee companies in which the organization has a shareholding position1053

Note: Business partners do not include subsidiaries and affiliates that the organization controls.

1054

business relationships

1055
1056
1057

relationships that the organization has with business partners, with entities in its value chain including
those beyond the first tier, and with any other entities directly linked to its operations, products, orservices

1058
1059

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

1060
1061
1062

Note: Examples of other entities directly linked to the organization’s operations, products, or services
are a non-governmental organization with which the organization delivers support to a local
community, or state security forces that protect the organization’s facilities.

1063

due diligence

1064
1065

process to identify, prevent, mitigate, and account for how the organization addresses its actual andpotential negative impacts

1066
1067
1068

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; and Organisation for Economic Cooperation and Development (OECD), OECD Guidelines for Multinational Enterprises, 2011; modified

1069

Note: See section 2.3 in GRI 1: Foundation 2021 for more information on ‘due diligence’.

1070

employee

1071
1072

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

1073

highest governance body1074

governance body with the highest authority in the organization

1075
1076
1077
1078

Note: In some jurisdictions, governance systems consist of two tiers, where supervision andmanagement are separated or where local law provides for a supervisory board drawn from nonexecutives to oversee an executive management board. In such cases, both tiers are included under
the definition of highest governance body.

Page 33 of 115

1079

human rights

1080
1081
1082
1083

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

1084
1085

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

1086
1087

Note: See Guidance to 2-23-b-i in GRI 2: General Disclosures 2021 for more information on ‘humanrights’.

1088

impact

1089
1090
1091

effect 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

1092
1093

Note 1: Impacts can be actual or potential, negative or positive, short-term or long-term, intended orunintended, and reversible or irreversible.

1094

Note 2: See section 2.1 in GRI 1: Foundation 2021 for more information on ‘impact’.

1095

local community

1096
1097

individuals or groups of individuals living or working in areas that are affected or that could be affectedby the organization’s activities

1098
1099

Note: The local community can range from those living adjacent to the organization’s operations tothose living at a distance.

1100

material topics

1101
1102

topics that represent the organization’s most significant impacts on the economy, environment, andpeople, including impacts on their human rights

1103
1104

Note: See section 2.2 in GRI 1: Foundation 2021 and section 1 in GRI 3: Material Topics 2021 formore information on ‘material topics’.

1105

mitigation

1106

action(s) taken to reduce the extent of a negative impact

1107
1108
1109
1110

Note: The mitigation of an actual negative impact refers to actions taken to reduce the severity of thenegative impact that has occurred, with any residual impact needing remediation. The mitigation of apotential negative impact refers to actions taken to reduce the likelihood of the negative impact
occurring.

1111
1112

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; modified

1113

remedy / remediation

1114

means to counteract or make good a negative impact / provision of remedy

1115
1116
1117

Examples: apologies, restitution, restoration, rehabilitation, financial or non-financial compensation,and punitive sanctions (whether criminal or administrative, such as fines), prevention of harm throughinjunctions or guarantees of non-repetition

1118
1119

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; modified

1120

reporting period1121

specific time period covered by the reported information

1122

Examples: fiscal year, calendar year

Page 34 of 115

1123

severity (of an impact)

1124
1125
1126

The severity of an actual or potential negative impact is determined by its scale (i.e., how grave theimpact is), scope (i.e., how widespread the impact is), and irremediable character (how hard it is tocounteract or make good the resulting harm).

1127
1128
1129

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; and the Organisation for Economic Co-operation and Development (OECD), OECD Due
Diligence Guidance for Responsible Business Conduct, 2018; modified

1130

Note: See section 1 in GRI 3: Material Topics 2021 for more information on ‘severity’.

1131

stakeholder

1132
1133

individual or group that has an interest that is affected or could be affected by the organization’s
activities

1134
1135

Source: Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018; modified

1136
1137
1138

Examples: business partners, civil society organizations, consumers, customers, employees andother workers, governments, local communities, non-governmental organizations, shareholders andother investors, suppliers, trade unions, vulnerable groups

1139

Note: See section 2.4 in GRI 1: Foundation 2021 for more information on ‘stakeholder’.

1140

supplier

1141
1142

entity upstream from the organization (i.e., in the organization’s supply chain), which provides a
product or service that is used in the development of the organization’s own products or services

1143
1144

Examples: brokers, consultants, contractors, distributors, franchisees, home workers, independent
contractors, licensees, manufacturers, primary producers, sub-contractors, wholesalers

1145
1146

Note: A supplier can have a direct business relationship with the organization (often referred to as
first-tier supplier) or an indirect business relationship.

1147

supply chain

1148
1149

range of activities carried out by entities upstream from the organization, which provide products orservices that are used in the development of the organization’s own products or services

1150

sustainable development / sustainability

1151
1152

development that meets the needs of the present without compromising the ability of future
generations to meet their own needs

1153

Source: World Commission on Environment and Development, Our Common Future, 1987

1154
1155

Note: In the GRI Standards, the terms ‘sustainability’ and ‘sustainable development’ are usedinterchangeably.

1156

vulnerable group

1157
1158
1159

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

1160
1161
1162
1163
1164
1165

Examples: children and youth; elderly persons; ex-combatants; HIV/AIDS-affected households;
human rights defenders; indigenous peoples; internally displaced persons; migrant workers and theirfamilies; national or ethnic, religious and linguistic minorities; persons who might be discriminatedagainst based on their sexual orientation, gender identity, gender expression, or sex characteristics(e.g., lesbian, gay, bisexual, transgender, intersex); persons with disabilities; refugees or returning
refugees; women

1166

Note: Vulnerabilities and impacts can differ by gender.

Page 35 of 115

1167

worker1168

person that performs work for the organization

1169
1170

Examples: employees, apprentices, interns, self-employed persons, and persons working fororganizations other than the reporting organization, such as for suppliers

1171
1172

Note: In the GRI Standards, in some cases it is specified whether a particular subset of workers is
required to be used.

Page 36 of 115

1173

Bibliography

1174

This section lists authoritative intergovernmental instruments used in developing this Standard.

1175

Authoritative instruments:

1176
1177

1. International Labour Organization (ILO), Tripartite Declaration of Principles concerning
Multinational Enterprises and Social Policy, 2017.

1178
1179

2. Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018.

1180
1181

3. Organisation for Economic Co-operation and Development (OECD), OECD Guidelines forMultinational Enterprises, 2011.

1182

4. United Nations (UN), Framework Convention on Climate Change (FCCC) Paris Agreement, 2015.

1183
1184

5. United Nations (UN), Guiding Principles on Business and Human Rights: Implementing the United
Nations “Protect, Respect and Remedy” Framework, 2011.

1185
1186

6. United Nations (UN), Protect, Respect and Remedy: a Framework for Business and Human
Rights, 2008.

1187
1188
1189

7. United Nations (UN), Report of the Special Representative of the Secretary-General on the Issueof Human Rights and Transnational Corporations and Other Business Enterprises, John Ruggie,
2011.

1190

8. World Commission on Environment and Development, Our Common Future, 1987.

Page 37 of 115

1191

GRI 2: General Disclosures 2021

1192

EFFECTIVE DATE: 1 JANUARY 2023

1193

UNIVERSAL STANDARD
Page 38 of 115

1194

GRI 2: General Disclosures 2021

1195

UNIVERSAL STANDARD

1196

Effective date

1197
1198

This Standard is effective for reports or other materials published on or after 1 January 2023. Earlier
adoption is encouraged.

1199

Responsibility

1200
1201

This Standard is issued by the Global Sustainability Standards Board (GSSB). Any feedback on the
GRI Standards can be submitted to ???@globalreporting.org for the consideration of the GSSB.

1202

Legal liability

1203
1204
1205
1206
1207
1208
1209
1210
1211
1212

This document, designed to promote sustainability reporting, has been developed by the Global
Sustainability Standards Board (GSSB) through a unique multi-stakeholder consultative process
involving representatives from organizations and report information users from around the world.
While the GRI Board of Directors and GSSB encourage use of the GRI Sustainability ReportingStandards (GRI Standards) and related Interpretations by all organizations, the preparation andpublication of reports based fully or partially on the GRI Standards and related Interpretations are thefull responsibility of those producing them. Neither the GRI Board of Directors, GSSB nor Stichting
Global Reporting Initiative (GRI) can assume responsibility for any consequences or damages
resulting directly or indirectly from the use of the GRI Standards and related Interpretations in the
preparation of reports, or the use of reports based on the GRI Standards and related Interpretations.

1213

Copyright and trademark notice

1214
1215
1216
1217
1218
1219

This document is copyright-protected by Stichting Global Reporting Initiative (GRI). The reproduction
and distribution of this document for information and/or use in preparing a sustainability report ispermitted without prior permission from GRI. However, neither this document nor any extract from it
may be reproduced, stored, translated, or transferred in any form or by any means (electronic,
mechanical, photocopied, recorded, or otherwise) for any other purpose without prior written
permission from GRI.

1220
1221

Global Reporting Initiative, GRI and logo, GSSB and logo, and GRI Sustainability ReportingStandards (GRI Standards) and logo are trademarks of Stichting Global Reporting Initiative.

1222© 2021 GRI. All rights reserved.

1223

ISBN 978-90-8866-NNN-N

Page 39 of 115

1224

Contents

1225

Introduction ........................................................................................................................................... 421226

1. The organization and its reporting practices ..................................................................................... 451227

Disclosure 2-1 Organizational details ............................................................................................ 45

1228

Disclosure 2-2 Entities included in the organization’s sustainability reporting .............................. 45

1229

Disclosure 2-3 Reporting period, frequency and contact point ...................................................... 46

1230

Disclosure 2-4 Restatements of information .................................................................................. 47

1231

Disclosure 2-5 External assurance ................................................................................................ 481232

2. Activities and workers ....................................................................................................................... 49

1233

Disclosure 2-6 Activities, value chain and other business relationships ....................................... 49

1234

Disclosure 2-7 Employees ............................................................................................................. 51

1235

Disclosure 2-8 Workers who are not employees ........................................................................... 56

1236

3. Governance ....................................................................................................................................... 58

1237

Disclosure 2-9 Governance structure and composition ................................................................. 58

1238

Disclosure 2-10 Nomination and selection of the highest governance body ................................. 59

1239

Disclosure 2-11 Chair of the highest governance body ................................................................. 59

1240
1241

Disclosure 2-12 Role of the highest governance body in overseeing the management of impacts ..
.......................................................................................................................................... 60

1242

Disclosure 2-13 Delegation of responsibility for managing impacts .............................................. 60

1243

Disclosure 2-14 Role of the highest governance body in sustainability reporting ......................... 61

1244

Disclosure 2-15 Conflicts of interest .............................................................................................. 61

1245

Disclosure 2-16 Communication of critical concerns ..................................................................... 62

1246

Disclosure 2-17 Collective knowledge of the highest governance body ....................................... 62

1247

Disclosure 2-18 Evaluation of the performance of the highest governance body ......................... 62

1248

Disclosure 2-19 Remuneration policies ......................................................................................... 63

1249

Disclosure 2-20 Process to determine remuneration .................................................................... 641250

Disclosure 2-21 Annual total compensation ratio .......................................................................... 64

1251

4. Strategy, policies and practices ........................................................................................................ 66

1252

Disclosure 2-22 Statement on sustainable development strategy ................................................ 66

1253

Disclosure 2-23 Policy commitments ............................................................................................. 671254

Disclosure 2-24 Embedding policy commitments .......................................................................... 69

1255

Disclosure 2-25 Processes to remediate negative impacts ........................................................... 71

1256

Disclosure 2-26 Mechanisms for seeking advice and raising concerns ........................................ 741257

Disclosure 2-27 Compliance with laws and regulations ................................................................ 75

1258

Disclosure 2-28 Membership associations .................................................................................... 76

1259

5. Stakeholder engagement .................................................................................................................. 77

1260

Disclosure 2-29 Approach to stakeholder engagement................................................................. 77

1261

Disclosure 2-30 Collective bargaining agreements ....................................................................... 78

Page 40 of 115

1262

Glossary ................................................................................................................................................ 80

1263

Bibliography .......................................................................................................................................... 85

Page 41 of 115

1264

Introduction

1265
1266
1267
1268

GRI 2: General Disclosures 2021 contains disclosures for organizations to provide information about
their reporting practices; activities and workers; governance; strategy, policies, and practices; andstakeholder engagement. This information gives insight into the profile and scale of organizations andprovides a context for understanding their impacts.

1269

The Standard is structured as follows:

1270
1271

•

Section 1 contains five disclosures, which provide information about the organization, itssustainability reporting practices, and the entities included in its sustainability reporting.

1272
1273

•

Section 2 contains three disclosures, which provide information about the organization’s
activities, employees, and other workers.

1274
1275

•

Section 3 contains thirteen disclosures, which provide information about the organization’s
governance structure, composition, roles, and remuneration.

1276
1277
1278

•

Section 4 contains seven disclosures, which provide information about the organization’ssustainable development strategy and its policies and practices for responsible businessconduct.

1279
1280
1281

•

Section 5 contains two disclosures, which provide information about the organization’s
stakeholder engagement practices and how it engages in collective bargaining with
employees.

1282
1283

•

The Glossary contains defined terms with a specific meaning when used in the GRI
Standards.

1284
1285
1286

•

The Bibliography lists authoritative intergovernmental instruments and additional referencesused in developing this Standard, as well as resources that can be consulted by theorganization.

1287
1288

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

1289

System of GRI Standards

1290
1291
1292
1293

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.

1294
1295
1296

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).

1297

Universal Standards: GRI 1, GRI 2 and GRI 3

1298
1299
1300

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.

1301
1302
1303

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.

1304
1305
1306

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.

Page 42 of 115

1307

Sector Standards

1308
1309
1310

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.

1311

Topic Standards

1312
1313
1314

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.

1315

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

1316

Using this Standard

1317
1318
1319
1320

An organization reporting in accordance with the GRI Standards is required to report all disclosures inthis Standard. Disclosure 2-2 in this Standard requires the organization to list its entities included in its
sustainability reporting. These entities define the scope for reporting all other disclosures in thisStandard.

1321

Reasons for omission are permitted for all disclosures in this Standard except for:

1322

•

Disclosure 2-1 Organizational details

1323

•

Disclosure 2-2 Entities included in the organization’s sustainability reporting

1324

•

Disclosure 2-3 Reporting period, frequency and contact point

1325

•

Disclosure 2-4 Restatements of information

1326

•

Disclosure 2-5 External assurance

Page 43 of 115

1327
1328
1329
1330
1331

If the organization cannot comply with a disclosure or with a requirement in a disclosure for which
reasons for omission are permitted (e.g., because the required information is confidential or subject tolegal prohibitions), the organization is required to specify the disclosure or the requirement it cannot
comply with, and provide a reason for omission together with an explanation in the GRI content index.
See Requirement 6 in GRI 1: Foundation 2021 for more information on reasons for omission.

1332
1333
1334
1335
1336

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.

1337
1338
1339
1340
1341

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).

1342

Requirements, guidance and defined terms

1343

The following apply throughout the GRI Standards:

1344
1345

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.

1346

Requirements may be accompanied by guidance.

1347
1348

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

1349
1350

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

1351

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

1352
1353

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.

Page 44 of 115

1354

1. The organization and its reporting

1355

practices

1356
1357

The disclosures in this section provide an overview of the organization, its sustainability reporting
practices, and the entities included in its sustainability reporting.

1358

Disclosure 2-1 Organizational details

1359

Requirements

1360

The organization shall:

1361

a. report its legal name;1362

b. report its nature of ownership and legal form;

1363

c. report the location of its headquarters;

1364

d. report its countries of operation.

1365

Guidance

1366

Guidance to 2-1-a

1367
1368

If the organization uses a commonly known trading name or business name that is different from its
legal name, it should report this in addition to its legal name.

1369

Guidance to 2-1-b

1370
1371
1372

The nature of ownership and the legal form of the organization refers to whether it is publicly or
privately owned, and whether it is an incorporated entity, a partnership, a sole proprietorship, or
another type of entity such as a nonprofit, an association, or a charity.

1373

Guidance to 2-1-c

1374
1375

Headquarters are an organization’s global administrative center, the place from which it is controlled
or directed.

1376

Guidance to 2-1-d

1377
1378
1379
1380
1381

If the organization has reported its countries of operation elsewhere, such as in its audited
consolidated financial statements or financial information filed on public record, the organization can
provide a link or reference to this information. The organization can also report the regions, or specificlocations within countries (e.g., states, cities) where it has operations, if this provides contextual
information for understanding the organization’s impacts.

1383

Disclosure 2-2 Entities included in the organization’s sustainability
reporting1384

Requirements

1385

The organization shall:

1386

a. list all its entities included in its sustainability reporting;

1382

Page 45 of 115

1387
1388
1389

b. if the organization has audited consolidated financial statements or financial information
filed on public record, specify the differences between the list of entities included in its
financial reporting and the list included in its sustainability reporting;

1390
1391

c. if the organization consists of multiple entities, explain the approach used forconsolidating the information, including:

1392

i.

whether the approach involves adjustments to information for minority interests;

1393
1394

ii.

how the approach takes into account mergers, acquisitions, and disposal ofentities or parts of entities;

1395
1396

iii.

whether and how the approach differs across the disclosures in this Standard andacross material topics.

1397

Guidance

1398

Guidance to 2-2-a

1399
1400

The entities reported under 2-2-a form the basis for reporting the disclosures in this Standard and for
determining the organization’s material topics.

1401
1402
1403
1404

Requirement 2-2-a includes those entities that the organization controls or has an interest in and havebeen included in its sustainability reporting, such as subsidiaries, joint ventures, and affiliates,
including minority interests. The organization should report information for the same group of entities
as covered in its financial reporting, in particular its financial reporting.

1405
1406
1407

When determining its material topics, the organization should consider the impacts of additional
entities with which it has business relationships that are not included in the list reported under 2-2-a.
See section 1 in GRI 3: Material Topics 2021 for more information.

1408

Guidance to 2-2-a and 2-2-b

1409
1410
1411
1412

If all the entities in the organization’s financial reporting are also included in its sustainability reporting,a brief statement of this fact, including a link or reference to the list of entities included in its audited
consolidated financial statements or financial information filed on public record, is sufficient to comply
with 2-2-a and 2-2-b.

1413
1414

The organization should separately specify any additional entities included in the sustainability
reporting that are not included in its financial reporting.

1415

Guidance to 2-2-c

1416

A minority interest is an ownership interest in an entity that is not controlled by the parent entity.

1417

Disclosure 2-3 Reporting period, frequency and contact point

1418

Requirements1419

The organization shall:1420

a. specify the reporting period for, and the frequency of, its sustainability reporting;

1421
1422

b. specify the reporting period for its financial reporting and, if it does not align with theperiod for its sustainability reporting, explain the reason for this;1423

c. report the publication date of the report or reported information;1424

d. specify the contact point for questions about the report or reported information.

Page 46 of 115

1425

Guidance

1426

Guidance to 2-3-a

1427
1428

The organization can specify the frequency of sustainability reporting as ‘annual’. See the Timelinessprinciple in GRI 1: Foundation 2021 for more information.

1429

Guidance to 2-3-a and 2-3-b

1430
1431
1432

The reporting period refers to the time period covered by the reported information and should include
the start and end dates (e.g., 1 January 2022 to 31 December 2022, 1 July 2022 through 30 June2023).

1433
1434
1435

The organization should report the information for the same reporting period as covered in its financial
reporting. The organization should also publish the information at the same time as its financial
reporting, where this is possible.

1436

Disclosure 2-4 Restatements of information

1437

Requirements

1438

The organization shall:

1439

a. report restatements of information made from previous reporting periods and explain:

1440

i.

the reasons for the restatements;

1441

ii.

the effect of the restatements.

1442

Guidance

1443
1444
1445
1446
1447
1448

The organization should provide a restatement of information when it has learned that the previously
reported information needs to be revised. Restatements of information from previous reporting
periods can correct an error, or account for changes in measurement methodology or to the nature of
the business. Restatements of information ensure consistency and enable comparability of
information between reporting periods. See the Comparability principle in GRI 1: Foundation 2021 formore information.

1449
1450
1451
1452

The organization should report the criteria it has used to determine when a change or error inpreviously reported information is considered significant enough to provide a restatement. A change
or error could be significant when it influences information users’ decision-making (e.g., it influences
the analysis of the changes in the organization’s impacts over time).

1453
1454
1455
1456
1457
1458
1459
1460

For example, if an organization adopts a new, more accurate method for measuring greenhouse gas(GHG) emissions, it may subsequently experience a reduction in its previously reported GHG
emissions that meets the organization’s restatement criteria. The organization then restates its
previously reported GHG emissions. In such a case, the organization is required to explain that it has
restated its previously reported GHG emissions due to the new measurement methodology, and that
this has resulted in lower GHG emissions than previously reported. The organization should also
report the quantitative change observed (e.g., GHG emissions are 10% lower compared to theemissions previously reported).

1461
1462

If the organization has not made any restatement in the reporting period, a brief statement of this fact
is sufficient to comply with the requirement.

1463

Guidance to 2-4-a-i

1464

Examples of reasons for restatements of information include:

1465

•

change of base period or length of reporting period;

1466

•

change in the nature of the business;

1467

•

change in the measurement methodologies or in the definitions used;

Page 47 of 115

1468

•

disposals, mergers, or acquisitions;

1469

•

error made in previous reporting periods.

1470

Guidance to 2-4-a-ii

1471
1472
1473
1474

The effect of the restatement refers to the consequences of the change or correction made topreviously reported information. If the restatement relates to quantitative information, the organization
should specify the quantitative change in the restated information (e.g., GHG emissions are 10%
lower compared to the level of emissions previously reported).

1475

Disclosure 2-5 External assurance

1476

Requirements

1477

The organization shall:

1478
1479

a. describe its policy and practice for seeking external assurance, including whether and how
the highest governance body and senior executives are involved;1480

b. if the organization’s sustainability reporting has been externally assured:

1481
1482

i.

provide a link or reference to the external assurance report(s) or assurance
statement(s);

1483
1484
1485

ii.

describe what has been assured and on what basis, including the assurance
standards used, the level of assurance obtained, and any limitations of theassurance process;

1486

iii.

describe the relationship between the organization and the assurance provider.

1487

Guidance1488

See section 5.2 in GRI 1: Foundation 2021 for information on external assurance.

1489

Guidance to 2-5-b-ii

1490
1491
1492

If this information is covered in the external assurance reports or statements that the organization has
provided a link or a reference to under 2-5-b-i, then a brief statement of this fact is sufficient to comply
with the requirement.

1493

The organization can also describe, in accessible language:

1494

•

the scope of information and processes covered;

1495

•

the responsibilities of the organization relative to the assurance provider;

1496

•

the opinion or conclusions formally signed off by the assurance provider;

1497

•

a summary of the work performed;

1498

•

information on the experience and qualifications of the assurance providers.

1499

Guidance to 2-5-b-iii

1500
1501
1502

An assurance provider conducting external assurance needs to demonstrate independence from theorganization to reach and publish objective and impartial conclusions about the organization’ssustainability reporting.

Page 48 of 115

1503

2. Activities and workers

1504
1505

The disclosures in this section provide an overview of the organization’s activities, employees, andother workers.

1506
1507

Disclosure 2-6 Activities, value chain and other business
relationships

1508

Requirements

1509

The organization shall:

1510

a. report the sector(s) in which it is active;1511

b. describe its value chain, including:

1512

i.

the organization’s activities, products, services, and markets served;

1513

ii.

the organization’s supply chain;

1514

iii.

the entities downstream from the organization and their activities;

1515

c. report other relevant business relationships;

1516
1517

d. describe significant changes in 2-6-a, 2-6-b, and 2-6-c compared to the previous reporting
period.

1518

Guidance

1519

Guidance to 2-6-a

1520
1521

Sectors can be identified according to categories, such as the public or private sector; or industryspecific categories, such as the education sector or the financial sector.

1522
1523
1524
1525

Depending on the organization’s activities, sectors can be identified using the GRI Sector Standards
or classification systems such as the Global Industry Classification Standard (GICS®), the Industry
Classification Benchmark (ICB), the International Standard Industrial Classification of All Economic
Activities (ISIC), and the Sustainable Industry Classification System (SICS®).

1526

Guidance to 2-6-b

1527
1528
1529
1530
1531
1532
1533

The organization’s value chain includes the range of activities carried out by the organization, and byentities upstream and downstream from the organization, to bring the organization’s products orservices from their conception to their end use. Entities upstream from the organization are those thatprovide products or services that are used in the development of the organization’s own products orservices. Entities downstream from the organization are those that receive products or services fromthe organization. Entities in the value chain include entities beyond the first tier, both upstream anddownstream.

1534
1535
1536
1537

The information reported under 2-6-b provides a context for understanding the organization’s impacts
across its value chain, including through use of its products and services. Describing the markets
served provides further information on the groups of customers targeted by the organization’s
products and services.

1538
1539

The organization is not required to provide a detailed description of each activity in its value chain.
Instead, it can provide a high-level overview of its value chain.

1540

Guidance to 2-6-b-i

1541
1542

When describing its activities, the organization should report its total number of operations andexplain how it defines ‘operation’.

Page 49 of 115

1543

When describing its products and services, the organization should report:

1544
1545

•

the quantity of products or services provided during the reporting period (e.g., number of
products or services provided, net sales of products or services provided);

1546
1547
1548

•

whether it sells products or services that are banned in certain markets or are the subject of
stakeholder concerns or public debate, including the reason for the ban or concerns, and how
the organization has responded to these concerns.

1549

When describing the markets served, the organization can report:

1550

•

the geographic locations where products and services are offered;

1551

•

the demographic or other characteristics of the markets;

1552

•

information on the size and relative importance of the markets (e.g., net sales, net revenues).

1553

Guidance to 2-6-b-ii

1554

The organization can describe:

1555

•

the types of suppliers (e.g., brokers, contractors, wholesalers);

1556
1557

•

the estimated number of suppliers throughout its supply chain and in each tier (e.g., first tier,second tier);

1558
1559

•

the types of activities related to the organization’s products and services carried out by its
suppliers (e.g., manufacturing, providing consulting services);

1560
1561

•

the nature of its business relationships with its suppliers (e.g., long-term or short-term,
contractual or non-contractual, project-based or event-based);

1562

•

the sector-specific characteristics of its supply chain (e.g., labor-intensive);

1563

•

the estimated monetary value of payments made to its suppliers;

1564

•

the geographic location of its suppliers.

1565

Guidance to 2-6-b-iii

1566

The organization can describe:

1567

•

the types of downstream entities (e.g., customers, beneficiaries);

1568

•

the estimated number of downstream entities;

1569
1570

•

the types of activities related to the organization’s products and services carried out by thedownstream entities (e.g., manufacturing, wholesale, retail);

1571
1572

•

the nature of its business relationships with the downstream entities (e.g., long-term or shortterm, contractual or non-contractual, project-based or event-based);

1573

•

the geographic location of the downstream entities.

1574

Guidance to 2-6-c

1575
1576
1577
1578

Other relevant business relationships include relationships that the organization has with entities thatare not described as part of its value chain under 2-6-b. These may include business partners (e.g.,
joint ventures) and other entities directly linked to the organization’s operations, products, or services(for examples, see the note in the definition of ‘business relationships’).

1579

The organization can report the types of entities, their activities, and their geographic location.

1580

Guidance to 2-6-d

1581
1582
1583
1584
1585
1586

Requirement 2-6-d entails describing significant changes in the organization’s sectors, value chain,and other business relationships compared to the previous reporting period. This information can help
explain changes to the organization’s impacts. Examples of significant changes that can be reported
under this disclosure are changes in activities such as the opening, closing, or expansion of facilities;changes in the structure of the organization’s supply chain or in its relationships with suppliers,
including selection and termination; or changes in the location of its suppliers.

Page 50 of 115

1587

Disclosure 2-7 Employees

1588

Requirements

1589

The organization shall:

1590
1591

a. report the total number of employees, and a breakdown of this total by gender and byregion;1592

b. report the total number of:

1593

i.

permanent employees, and a breakdown by gender and by region;

1594

ii.

temporary employees, and a breakdown by gender and by region;

1595

iii.

non-guaranteed hours employees, and a breakdown by gender and by region;

1596

iv.

full-time employees, and a breakdown by gender and by region;

1597

v.

part-time employees, and a breakdown by gender and by region;

1598
1599

c. describe the methodologies and assumptions used to compile the data, including whether
the numbers are reported:

1600

i.

in head count, full-time equivalent (FTE), or using another methodology;

1601
1602

ii.

at the end of the reporting period, as an average across the reporting period, orusing another methodology;

1603
1604

d. report contextual information necessary to understand the data reported under 2-7-a and2-7-b;

1605
1606

e. describe significant fluctuations in the number of employees during the reporting period
and between reporting periods.

1607

Guidance

1608
1609
1610
1611
1612
1613

This disclosure, together with Disclosure 2-8, gives insight into the organization’s approach to
employment, as well as the scope and nature of impacts arising from its employment practices. It also
provides contextual information that aids an understanding of the information reported in otherdisclosures, and it serves as the basis for calculation in other disclosures, such as Disclosure 2-21
Annual total compensation ratio and Disclosure 2-30 Collective bargaining agreements in thisStandard.

1614
1615

This disclosure covers all employees who perform work for any of the organization’s entities included
in its sustainability reporting as reported under Disclosure 2-2 in this Standard.

1616

See references [7], [19], [22], [23], [24], [26], and [30] in the Bibliography.

1617

Guidance to 2-7-a

1618
1619

An employee is an individual who is in an employment relationship with the organization according tonational law or practice.

1620
1621
1622

Providing a breakdown of employees by gender gives insight into gender representation across theorganization. Providing a breakdown of employees by region gives insight into regional variations.
Region can refer to a country or to other geographic locations, such as cities or world regions.

1623

See Table 1 and Table 2 of this Standard for examples of how to present this information.

1624

Guidance to 2-7-b

1625
1626

The definitions of permanent, temporary, non-guaranteed hours, full-time, and part-time employees
differ between countries. If the organization has employees in more than one country, it should use

Page 51 of 115

1627
1628
1629

the definitions as per the national laws of the countries where the employees are based to calculate
country-level data. The country-level data should then be added up to calculate total numbers,
disregarding differences in national legal definitions.

1630
1631
1632
1633
1634

Non-guaranteed hours employees are employed by the organization without a guarantee of aminimum or fixed number of working hours. The employee may need to make themselves available
for work as required, but the organization is not contractually obligated to offer the employee aminimum or fixed number of working hours per day, week, or month. Casual employees, employeeswith zero-hour contracts, and on-call employees are examples that fall under this category.

1635
1636
1637

If the organization is unable to report exact figures, it can report estimates of the number of
employees to the nearest ten or, where the number of employees is greater than 1,000, to the nearest
100, and explain this under 2-7-c.

1638

See Table 1 and Table 2 of this Standard for examples of how to present this information.

1639

Guidance to 2-7-c

1640
1641
1642
1643
1644

The organization can report the total number of employees and the number of permanent, temporary,non-guaranteed hours, full-time, and part-time employees in head count or full-time equivalent (FTE).
Reporting these numbers in head count gives insight into the number of individual employees,
whether on a full-time or part-time basis. Reporting these numbers in FTE gives insight into the hours
worked.

1645

The organization can use another methodology for reporting these numbers.

1646
1647
1648

Reporting the number of employees at the end of the reporting period provides information for thatpoint in time, without capturing fluctuations during the reporting period. Reporting these numbers inaverages across the reporting period takes into account fluctuations during the reporting period.

1649

Guidance to 2-7-d

1650
1651
1652
1653
1654

Quantitative data, such as the number of temporary or part-time employees, is unlikely to be sufficienton its own. For example, a high proportion of temporary or part-time employees could indicate lack of
employment security for employees, but it could equally signal workplace flexibility when offered as avoluntary choice. For this reason, the organization is required to report contextual information to help
information users interpret the data.

1655
1656
1657
1658
1659

The organization can explain the reasons for temporary employment. An example of such a reason is
the recruitment of employees to undertake work on a temporary or seasonal project or event. Anotherexample is that it is standard practice to offer a temporary contract (e.g., 6 months) to new employees
prior to the offer of permanent employment. The organization can also explain the reasons for nonguaranteed hours employment.

1660
1661
1662
1663
1664

The organization can explain how it defines full-time employment. If the organization has employees
in more than one country, it can report the definitions of full-time employment it uses for the regionsthat cover these countries. The organization can also explain the reasons for part-time employment.
Examples of such reasons are to accommodate employees’ requests to work reduced hours, or
because the organization is unable to provide full-time employment to all employees.

1665
1666
1667

If there are differences in permanent, temporary, non-guaranteed hours, full-time, and part-time
employment between genders or between regions, the organization can explain the reasons for thesedifferences.

1668

Guidance to 2-7-e

1669
1670
1671
1672
1673
1674

Requirement 2-7-e enables the organization to explain how the numbers of employees vary during
the reporting period or in comparison to the previous reporting periods (i.e., whether the numbers
have increased or decreased). It can also include the reasons for the fluctuations. For example, anincrease in the number of employees during the reporting period could be due to a seasonal event. A
decrease in the number of employees in comparison to the previous reporting period could be due tothe completion of a temporary project.

1675
1676
1677

It is up to the organization to determine which fluctuations in the number of employees it considers
significant to report under 2-7-e. The organization should report its threshold for determining
significant fluctuations.

Page 52 of 115

1678
1679

If there are no significant fluctuations in the number of employees during the reporting period or
between reporting periods, a brief statement of this fact is sufficient to comply with the requirement.

1680

Table 1. Example template for presenting information on employees by gender[Reporting period]
Number of employees (head count / FTE)
Total

[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]Number of permanent employees (head count / FTE)
Total

[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]Number of temporary employees (head count / FTE)
Total

[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]Number of non-guaranteed hours employees (head count / FTE)
Total

[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]Number of full-time employees (head count / FTE)
Total

[Number]

Female[Number]

Page 53 of 115

Male[Number]

Other gendercategory*[Number]Not disclosed[Number]Number of part-time employees (head count / FTE)

1681

Total

[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]* As specified by the employees themselves.

Page 54 of 115

1682

Table 2. Example template for presenting information on employees by region[Reporting period]
Number of employees (head count / FTE)
Total

[Number]

Region A[Number]

Region B[Number]Number of permanent employees (head count / FTE)
Total

[Number]

Region A[Number]

Region B[Number]Number of temporary employees (head count / FTE)
Total

[Number]

Region A[Number]

Region B[Number]Number of non-guaranteed hours employees (head count / FTE)
Total

[Number]

Region A[Number]

Region B[Number]Number of full-time employees (head count / FTE)
Total

[Number]

Region A[Number]

Region B[Number]Number of part-time employees (head count / FTE)
Total

[Number]

Region A[Number]

Region B[Number]

Page 55 of 115

1683

Disclosure 2-8 Workers who are not employees

1684

Requirements

1685

The organization shall:

1686
1687

a. report the total number of workers who are not employees and whose work is controlled
by the organization and describe:

1688
1689

i.

the most common types of worker and their contractual relationship with theorganization;

1690

ii.

the type of work they perform;

1691
1692

b. describe the methodologies and assumptions used to compile the data, including whether
the number of workers who are not employees is reported:

1693

i.

in head count, full-time equivalent (FTE), or using another methodology;

1694
1695

ii.

at the end of the reporting period, as an average across the reporting period, orusing another methodology;

1696
1697

c. describe significant fluctuations in the number of workers who are not employees during
the reporting period and between reporting periods.

1698

Guidance

1699
1700
1701
1702

This disclosure provides an understanding of how much the organization relies on workers who are
not employees to perform its work, in comparison to employees. This information is important forunderstanding how many workers in total perform work for the organization, because workers who are
not employees are not represented in employment figures reported under Disclosure 2-7.

1703
1704
1705
1706

Disclosure 2-8, together with Disclosure 2-7, gives insight into the organization’s approach to
employment, as well as the scope and nature of impacts arising from its employment practices. It also
provides contextual information that aids an understanding of the information reported in otherdisclosures.

1707
1708
1709

This disclosure covers all workers who are not employees and whose work is controlled by any of theorganization’s entities included in its sustainability reporting as reported under Disclosure 2-2 in thisStandard.

1710
1711
1712

If all the workers performing work for the organization are employees and the organization does notengage any workers who are not employees, a brief statement of this fact is sufficient to comply withthe requirements under this disclosure.

1713

See references [7], [19], [22], [23], [24], [26], and [30] in the Bibliography.

1714

Guidance to 2-8-a

1715
1716

Workers who are not employees are those who perform work for the organization but are not in an
employment relationship with the organization.

1717
1718
1719

This disclosure requires the organization to report the number of workers who are not employees andwhose work is controlled by the organization. Control of work implies that the organization directs thework performed or has control over the means or methods for performing the work.

1720
1721
1722
1723
1724
1725

The organization might have sole control of the work or share control with one or more organizations(e.g., suppliers, customers, or other business partners, such as in joint ventures). Types of workers
who are not employees and whose work is controlled by the organization include agency workers,
apprentices, contractors, home workers, interns, self-employed persons, sub-contractors, andvolunteers. The organization should report how it has determined when it has control of the work forworkers who are not employees.

Page 56 of 115

1726
1727

The following are examples of workers who are not employees and whose work is controlled by theorganization. The following workers are included under this disclosure:

1728
1729

•

Contractors hired by the organization to perform work at the organization’s workplace, in a
public area (e.g., on a road), or directly at the workplace of the organization’s client.

1730
1731
1732

•

Workers of one of the organization’s supplier, where the organization instructs the supplier touse particular materials or work methods in manufacturing the products or delivering theservices.

1733•

Volunteers or interns performing work for the organization.

1734
1735

The following are examples of workers who are not employees and whose work is not controlled by
the organization. The following workers are not included under this disclosure:

1736
1737
1738

•

Workers of an equipment supplier to the organization who perform regular maintenance on
the supplier’s equipment (e.g., photocopy machines at the organization’s workplace) as
stipulated in the contract between the equipment supplier and the organization.

1739
1740
1741

•

Workers of one of the organization’s supplier, if the organization sources standard productsthat are manufactured using the supplier’s production methods (e.g., purchasing stationery
that is a standard product of the supplier).

1742
1743
1744

If the organization is unable to report exact figures, it can report estimates of the number of workers
who are not employees to the nearest ten or, where the number of workers who are not employees isgreater than 1,000, to the nearest 100, and explain this under 2-8-b.

1745

Guidance to 2-8-a-i and 2-8-a-ii

1746
1747
1748

When reporting its contractual relationship with the most common types of worker, the organization
should report whether it engages them directly or indirectly through a third party, and in the latter
case, who this third party is (e.g., employment agency, contractor).

1749
1750
1751

It is sufficient that the organization provides a general description. The organization is not required toreport the type of worker, contractual relationship, and work performed for every worker who is not an
employee.

1752

Guidance to 2-8-b

1753
1754
1755
1756

The organization can report the number of workers who are not employees in head count or full-time
equivalent (FTE). The head count gives insight into the number of individual workers, whether on afull-time or part-time basis. The FTE gives insight into the hours worked. The organization can use
another methodology for reporting this number.

1757
1758
1759
1760

Reporting the number of workers who are not employees at the end of the reporting period provides
information for that point in time, without capturing fluctuations during the reporting period. Reporting
this number as an average across the reporting period takes into account fluctuations during thereporting period.

1761

Guidance to 2-8-c

1762
1763
1764
1765
1766
1767
1768

Requirement 2-8-c enables the organization to explain how the number of workers who are not
employees varies during the reporting period or in comparison to previous reporting periods (i.e.,
whether the numbers have increased or decreased). It can also include the reasons for thefluctuations. For example, an increase in the number of workers who are not employees during thereporting period could be due to a seasonal event. A decrease in the number of workers who are not
employees in comparison to the previous reporting period could be due to the completion of atemporary project.

1769
1770
1771

It is up to the organization to determine which fluctuations in the number of workers it considers
significant to report under 2-8-c. The organization should report its threshold for determining
significant fluctuations.

1772
1773
1774

If there are no significant fluctuations in the number of workers who are not employees during thereporting period or between reporting periods, a brief statement of this fact is sufficient to comply withthe requirement.

Page 57 of 115

1775

3. Governance

1776
1777

The disclosures in this section provide information about the organization’s governance structure,composition, knowledge, roles, and remuneration.

1778
1779
1780
1781
1782
1783

The information reported under these disclosures is important for an understanding of how the
management of the organization’s impacts on the economy, environment, and people, including
impacts on their human rights, is integrated into the organization’s strategy and operations. It
addresses how the governance bodies are set up and how well equipped they are to oversee themanagement of the organization’s impacts. It also facilitates an understanding of the role and the
responsibilities of governance bodies with respect to these impacts.

1784
1785
1786
1787
1788

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).

1789

Disclosure 2-9 Governance structure and composition

1790

Requirements

1791

The organization shall:

1792

a. describe its governance structure, including committees of the highest governance body;

1793
1794
1795

b. list the committees of the highest governance body that are responsible for decisionmaking on and overseeing the management of the organization’s impacts on the economy,
environment, and people;

1796

c. describe the composition of the highest governance body and its committees by:

1797

i.

executive and non-executive members;

1798

ii.

independence;

1799

iii.

tenure of members on the governance body;

1800
1801

iv.

number of other significant positions and commitments held by each member, andthe nature of the commitments;

1802

v.

gender;1803

vi.

under-represented social groups;

1804

vii.

competencies relevant to the impacts of the organization;

1805

viii.

stakeholder representation.

1806

Guidance

1807

Guidance to 2-9-c

1808
1809
1810

The organization can describe the composition of the highest governance body and its committees byadditional indicators of diversity, such as age, ancestry and ethnic origin, citizenship, creed, disability,
or any other indicators of diversity that are relevant for reporting.

1811

Guidance to 2-9-c-ii

1812
1813

‘Independence’ refers to conditions that enable the members of the highest governance body to
exercise independent judgement free from any external influence or conflicts of interest. See

Page 58 of 115

1814
1815

reference [20] in the Bibliography for more information on independence criteria for governancebodies.

1816

Guidance to 2-9-c-iv

1817
1818
1819

A position or commitment held by a highest governance body member is significant when the timeand attention it demands compromises the member’s ability to perform its duties in the organization.
Significant positions can include cross-board memberships.

1820

Guidance to 2-9-c-vii

1821
1822

Competencies relevant to the impacts of the organization include competencies relevant to impacts
commonly associated with the organization’s sectors, products, and geographic locations.

1823
1824

Disclosure 2-10 Nomination and selection of the highest
governance body

1825

Requirements

1826

The organization shall:

1827
1828

a. describe the nomination and selection processes for the highest governance body and its
committees;

1829
1830

b. describe the criteria used for nominating and selecting highest governance bodymembers, including whether and how the following are taken into consideration:

1831

i.

views of stakeholders (including shareholders);

1832

ii.

diversity;

1833

iii.

independence;

1834

iv.

competencies relevant to the impacts of the organization.

1835

Guidance

1836

Guidance to 2-10-b-iii

1837
1838
1839
1840

‘Independence’ refers to conditions that enable the members of the highest governance body to
exercise independent judgement free from any external influence or conflicts of interest. Seereference [20] in the Bibliography for more information on independence criteria for governancebodies.

1841

Guidance to 2-10-b-iv

1842
1843

Competencies relevant to the impacts of the organization include competencies relevant to impacts
commonly associated with the organization’s sectors, products, and geographic locations.

1844

Disclosure 2-11 Chair of the highest governance body

1845

Requirements

1846

The organization shall:

1847
1848

a. report whether the chair of the highest governance body is also a senior executive in theorganization;

Page 59 of 115

1849
1850
1851

b. if the chair is also a senior executive, explain their function within the organization’s
management, the reasons for this arrangement, and how conflicts of interest are prevented
and mitigated.

1852
1853

Disclosure 2-12 Role of the highest governance body in overseeing
the management of impacts

1854

Requirements

1855

The organization shall:

1856
1857
1858

a. describe the role of the highest governance body and of senior executives in developing,approving, and updating the organization’s purpose, value or mission statements,
strategies, policies, and goals related to sustainable development;

1859
1860
1861

b. describe the role of the highest governance body in overseeing the organization’s due
diligence and other processes to identify and manage the organization’s impacts on theeconomy, environment, and people, including:

1862
1863

i.

whether and how the highest governance body engages with stakeholders to
support these processes;

1864

ii.

how the highest governance body considers the outcomes of these processes;

1865
1866

c. describe the role of the highest governance body in reviewing the effectiveness of theorganization’s processes as described in 2-12-b, and report the frequency of this review.

1867

Guidance

1868
1869

For more information about the role of the highest governance body in overseeing the management of
the organization’s impacts, see reference [20] in the Bibliography.

1870

Guidance to 2-12-b-i

1871
1872
1873

Requirement 2-12-b-i covers the role of the highest governance body in stakeholder engagement.
The organization is also required to report information about stakeholder engagement under otherdisclosures, such as under the disclosures in section 5 of this Standard.

1874
1875
1876
1877

The organization can describe the frequency of engagement between the highest governance bodyand stakeholders as well as the means of engagement. If stakeholder engagement is delegated, theorganization can report to whom it is delegated, and how the feedback received is provided to thehighest governance body.

1878

Disclosure 2-13 Delegation of responsibility for managing impacts

1879

Requirements

1880

The organization shall:

1881
1882

a. describe how the highest governance body delegates responsibility for managing theorganization’s impacts on the economy, environment, and people, including:

1883
1884

i.

whether it has appointed any senior executives with responsibility for the
management of impacts;

1885
1886

ii.

whether it has delegated responsibility for the management of impacts to other
employees;

Page 60 of 115

1887
1888
1889

b. describe the process and frequency for senior executives or other employees to reportback to the highest governance body on the management of the organization’s impacts on
the economy, environment, and people.

1890
1891

Disclosure 2-14 Role of the highest governance body insustainability reporting

1892

Requirements

1893

The organization shall:

1894
1895
1896

a. report whether the highest governance body is responsible for reviewing and approving
the reported information, including the organization’s material topics, and if so, describe
the process for reviewing and approving the information;

1897
1898
1899

b. if the highest governance body is not responsible for reviewing and approving thereported information, including the organization’s material topics, explain the reason for
this.

1900

Guidance

1901
1902
1903
1904
1905
1906
1907

The organization can report whether the highest governance body has established a sustainability
reporting committee to support the highest governance body’s review and approval process. The
organization can also report whether the highest governance body reviews the adequacy of theorganization’s internal controls to strengthen the integrity and credibility of the organization’ssustainability reporting (see section 5.2 in GRI 1: Foundation 2021 for more information). The
involvement of the highest governance body and senior executives in developing the organization’s
policy and practice for seeking external assurance is reported under Disclosure 2-5 in this Standard.

1908

Disclosure 2-15 Conflicts of interest

1909

Requirements

1910

The organization shall:

1911
1912

a. describe the processes for the highest governance body to ensure that conflicts of interest
are prevented and mitigated;

1913
1914

b. report whether conflicts of interest are disclosed to stakeholders, including, at a minimum,
conflicts of interest relating to:

1915

i.

cross-board membership;

1916

ii.

cross-shareholding with suppliers and other stakeholders;

1917

iii.

existence of controlling shareholders;

1918

iv.

related parties, their relationships, transactions, and outstanding balances.

1919

Guidance

1920

See reference [20] in the Bibliography.

1921

Guidance to 2-15-b-iii

1922
1923

The organization should use the definition of controlling shareholder applied in the organization’s
consolidated financial statements or equivalent documents.

Page 61 of 115

1924

Disclosure 2-16 Communication of critical concerns

1925

Requirements

1926

The organization shall:

1927
1928

a. describe whether and how critical concerns are communicated to the highest governance
body;

1929
1930

b. report the total number and the nature of critical concerns that were communicated to thehighest governance body during the reporting period.

1931

Guidance

1932
1933
1934
1935
1936

Critical concerns include concerns about the organization’s potential and actual negative impacts on
stakeholders raised through grievance mechanisms and other processes. They also include
concerns, identified through other mechanisms, about the organization’s business conduct in its
operations and its business relationships. See guidance to Disclosure 2-25 and Disclosure 2-26 in thisStandard for more information.

1937
1938

Disclosure 2-17 Collective knowledge of the highest governance
body

1939

Requirements

1940

The organization shall:

1941
1942

a. report measures taken to advance the collective knowledge, skills, and experience of thehighest governance body on sustainable development.

1943
1944

Disclosure 2-18 Evaluation of the performance of the highest
governance body

1945

Requirements

1946

The organization shall:

1947
1948
1949

a. describe the processes for evaluating the performance of the highest governance body inoverseeing the management of the organization’s impacts on the economy, environment,
and people;

1950
1951

b. report whether the evaluations are independent or not, and the frequency of theevaluations;

1952
1953

c. describe actions taken in response to the evaluations, including changes to thecomposition of the highest governance body and organizational practices.

Page 62 of 115

1954

Disclosure 2-19 Remuneration policies

1955

Requirements

1956

The organization shall:

1957
1958

a. describe the remuneration policies for members of the highest governance body andsenior executives, including:

1959

i.

fixed pay and variable pay;

1960

ii.

sign-on bonuses or recruitment incentive payments;

1961

iii.

termination payments;

1962

iv.

clawbacks;

1963

v.

retirement benefits;

1964
1965
1966

b. describe how the remuneration policies for members of the highest governance body andsenior executives relate to their objectives and performance in relation to the managementof the organization’s impacts on the economy, environment, and people.

1967

Guidance

1968

Guidance to 2-19-a-i

1969
1970

Fixed pay and variable pay can include performance-based pay, equity-based pay, bonuses, anddeferred and vested shares.

1971
1972

If the organization uses performance-based pay, it should describe how remuneration for senior
executives is designed to reward long-term performance.

1973

Guidance to 2-19-a-iii

1974
1975
1976
1977

Termination payments are all payments and benefits given to a departing member of the highest
governance body or senior executive whose appointment is terminated. Termination payments extend
beyond monetary payments, from transferring property to automatic or accelerated vesting of
incentives.

1978

If the organization provides termination payments, it should explain whether:

1979
1980

•

notice periods for highest governance body members and senior executives are different fromthose for other employees;

1981
1982

•

termination payments for highest governance body members and senior executives aredifferent from those for other employees;

1983
1984

•

departing highest governance body members and senior executives receive payments otherthan those related to the notice period;

1985

•

any mitigation clauses that are included in the termination arrangements.

1986

Guidance to 2-19-a-iv

1987
1988
1989

Clawbacks are repayments of previously received compensation that a highest governance bodymember or senior executive is required to make to their employer in the event that certain conditionsof employment or goals are not met.

1990

Guidance to 2-19-a-v

1991
1992
1993

The organization should report the differences between the retirement benefit schemes and thecontribution rates for the highest governance body members, senior executives, and all other
employees.

Page 63 of 115

1994

Disclosure 2-20 Process to determine remuneration

1995

Requirements

1996

The organization shall:

1997
1998

a. describe the process for designing its remuneration policies and for determining
remuneration, including:

1999
2000

i.

whether independent highest governance body members or an independent
remuneration committee oversees the process for determining remuneration;

2001
2002

ii.

how the views of stakeholders (including shareholders) regarding remuneration
are sought and taken into consideration;

2003
2004
2005

iii.

whether remuneration consultants are involved in determining remuneration and, if
so, whether they are independent from the organization, its highest governancebody and senior executives;

2006
2007

b. report the results of votes of stakeholders (including shareholders) on remuneration
policies and proposals, if applicable.

2008

Guidance

2009
2010
2011
2012

Remuneration policies are established to ensure that the remuneration arrangements help recruit,
motivate, and retain highest governance body members, senior executives, and other employees,
while supporting the organization’s strategy and its contribution to sustainable development, andaligning with the interests of stakeholders.

2013

Disclosure 2-21 Annual total compensation ratio

2014

Requirements

2015

The organization shall:

2016
2017
2018

a. report the ratio of the annual total compensation for the organization’s highest-paid
individual to the median annual total compensation for all employees (excluding thehighest-paid individual);

2019
2020
2021

b. report the ratio of the percentage increase in annual total compensation for theorganization’s highest-paid individual to the median percentage increase in annual totalcompensation for all employees (excluding the highest-paid individual);

2022
2023

c. report contextual information necessary to understand the data and how the data has been
compiled.

2024

Guidance

2025

Guidance to 2-21-a and 2-21-b

2026

This disclosure covers all employees as reported under Disclosure 2-7 in this Standard.

2027
2028
2029
2030

Annual total compensation includes salary, bonus, stock awards, option awards, non-equity incentive
plan compensation, change in pension value, and nonqualified deferred compensation earnings
provided over the course of a year. When calculating the ratio, the organization should, depending on
the organization’s remuneration policies and availability of data, consider all of the following:

2031
2032

•

Base salary, which is the sum of guaranteed, short-term, and non-variable cash
compensation.

Page 64 of 115

2033
2034

•

Total cash compensation, which is the sum of the base salary and cash allowances, bonuses,
commissions, cash profit-sharing, and other forms of variable cash payments.

2035
2036
2037
2038

•

Direct compensation, which is the sum of total cash compensation and total fair value of allannual long-term incentives (e.g., stock option awards, restricted stock shares or units,
performance stock shares or units, phantom stock shares, stock appreciation rights, long-term
cash awards).

2039

The annual total compensation ratio can be calculated using the following formula:

2040

Annual total compensation for the organization's highest paid-individual
Median annual total compensation for all of the organization's employees excluding the highest-paid individual

2041

The change in the annual total compensation ratio can be calculated using the following formula:

2042

Percentage increase in annual total compensation for the organization's highest paid-individual
Median percentage increase in annual total compensation for all of the organization's employees excluding the highest-paid individual

2043

Guidance to 2-21-c

2044
2045
2046
2047

Quantitative data, such as the annual total compensation ratio, may not be sufficient on its own tounderstand pay disparity and its drivers. For example, pay ratios can be influenced by the size of theorganization (e.g., revenue, number of employees), its sector, its employment strategy (e.g., relianceon outsourced workers or part-time employees, a high degree of automation), or currency volatility.

2048
2049
2050
2051
2052
2053

The difference in pay disparity reported over the years may be the result of a change in theorganization’s compensation policy or the level of compensation for its highest paid individual or
employees, a change in calculation methodology (e.g., selection of the median annual totalcompensation, inclusions or exclusions) or an improvement in data collection processes. For thisreason, the organization is required to report contextual information to help information users interpretthe data and understand how it has been compiled.

2054

The organization should provide the following contextual information:

2055

•

Whether any employees reported under Disclosure 2-7 in this Standard have been excluded.

2056

•

Whether full-time equivalent (FTE) pay rates are used for each part-time employee.

2057

•

A list of the types of compensation included.

2058

•

The title of the highest-paid individual.

Page 65 of 115

2059

4. Strategy, policies and practices

2060
2061
2062

The disclosures in this section provide information about the organization’s sustainable development
strategy and its policies and practices for responsible business conduct. The disclosures are basedon expectations for businesses contained in authoritative intergovernmental instruments.1

2063
2064
2065
2066
2067
2068

Expectations for responsible business conduct include complying with laws and regulations;
respecting all internationally recognized human rights, including the rights of workers; and protecting
the environment and public health and safety. The expectations also cover combating bribery, bribe
solicitation, extortion, and other forms of corruption; adhering to good tax practices; and conducting
due diligence to identify, prevent, mitigate, and account for how the organization addresses its
negative impacts on the economy, environment, and people, including impacts on their human rights.

2069
2070
2071
2072
2073
2074

In the disclosures in this section, the organization is required to report information about its overall
policies and practices for responsible business conduct, rather than information for specific material
topics. Disclosure 3-3 in GRI 3: Material Topics 2021 requires information about how the organization
manages each material topic. If the organization has described its policies and practices for a material
topic under the disclosures in this section, it can provide a reference to this information under
Disclosure 3-3 in GRI 3 and does not need to repeat the information.

2075

Disclosure 2-22 Statement on sustainable development strategy

2076

Requirements

2077

The organization shall:

2078
2079
2080

a. report a statement from the highest governance body or most senior executive of theorganization about the relevance of sustainable development to the organization and its
strategy for contributing to sustainable development.

2081

Guidance2082

The organization should describe:

2083
2084
2085

•

its short, medium, and long-term vision and strategy to manage its impacts on the economy,
environment, and people, including impacts on their human rights, across the organization’s
activities and business relationships;

2086
2087

•

how its purpose, business strategy, and business model aim to prevent negative impacts andachieve positive impacts on the economy, environment, and people;

2088
2089

•

its short and medium-term strategic priorities for contributing to sustainable development,
including how the priorities are aligned with authoritative intergovernmental instruments;

2090
2091

•

the broader trends (e.g., macroeconomic, social, political) affecting the organization and its
strategy for contributing to sustainable development;

2092
2093

•

the key events, achievements, and failures associated with the organization’s contribution tosustainable development during the reporting period;

1 These instruments include the International Labour Organization (ILO) Tripartite Declaration of Principles

concerning Multinational Enterprises and Social Policy [9]; the Organisation for Economic Co-operation andDevelopment (OECD) Guidelines for Multinational Enterprises [12]; the OECD Due Diligence Guidance for
Responsible Business Conduct [11]; and the United Nations (UN) Guiding Principles on Business and Human
Rights [14]. These instruments are in turn based on international legal instruments, such as the United Nations(UN) International Bill of Human Rights [15] and the ILO conventions.

Page 66 of 115

2094
2095

•

a view of performance against goals and targets related to the organization’s material topics
during the reporting period;

2096
2097

•

the organization’s main challenges, goals, and targets regarding its contribution to sustainable
development for the next year and the coming three to five years.

2098

Disclosure 2-23 Policy commitments

2099

Requirements

2100

The organization shall:

2101

a. describe its policy commitments for responsible business conduct, including:

2102

i.

the authoritative intergovernmental instruments that the commitments reference;

2103

ii.

whether the commitments stipulate conducting due diligence;

2104

iii.

whether the commitments stipulate applying the precautionary principle;

2105

iv.

whether the commitments stipulate respecting human rights;

2106

b. describe its specific policy commitment to respect human rights, including:

2107

i.

the internationally recognized human rights that the commitment covers;

2108
2109

ii.

the categories of stakeholders, including at-risk or vulnerable groups, that theorganization gives particular attention to in the commitment;

2110
2111

c. provide links to the policy commitments if publicly available, or, if the policy commitments
are not publicly available, explain the reason for this;

2112
2113

d. report the level at which each of the policy commitments was approved within theorganization, including whether this is the most senior level;

2114
2115

e. report the extent to which the policy commitments apply to the organization’s own
activities and to its business relationships;

2116
2117

f.

2118

Guidance

2119
2120
2121
2122

This disclosure covers the organization’s policy commitments for responsible business conduct,
including the commitment to respect human rights. These commitments can be set out in a standalone policy document or they can be included within one or more other policy documents, such ascodes of conduct.

2123
2124
2125
2126

The Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational
Enterprises [12], the OECD Due Diligence Guidance for Responsible Business Conduct [11], and theUnited Nations (UN) Guiding Principles on Business and Human Rights [14] set out expectations fororganizations in relation to these policy commitments.

2127

Guidance to 2-23-a

2128
2129

The organization should report the expectations, values, principles, and norms of behavior set out inthe policy commitments.

2130
2131

The organization can also report how the policy commitments were developed, including the internaland external expertise that informed the policy commitments.

2132

Guidance to 2-23-a-i

2133
2134

See the Bibliography for a list of authoritative intergovernmental instruments for responsible businessconduct.

describe how the policy commitments are communicated to workers, business partners,
and other relevant parties.

Page 67 of 115

2135

The organization can also make a reference to other standards or initiatives that it participates in.

2136

Guidance to 2-23-a-iii

2137
2138
2139
2140

The precautionary principle is set out in Principle 15 of the UN Rio Declaration on Environment andDevelopment [18]. It states: ‘Where there are threats of serious or irreversible damage, lack of fullscientific certainty shall not be used as a reason for postponing cost-effective measures to prevent
environmental degradation.’

2141
2142
2143

The precautionary principle means taking early action to prevent and mitigate potential negative
impacts in situations where conclusive scientific understanding or evidence is lacking but there issufficient reason to expect serious or irreversible damage.

2144
2145
2146

While the precautionary principle is most often associated with the protection of the environment, it
can be applied to other areas, such as health and safety. The organization can describe the areas
where it applies the precautionary principle.

2147
2148
2149

The application of the precautionary principle can be reported under 3-3-d-i in GRI 3: Material Topics
2021, as part of the organization’s actions to prevent or mitigate potential negative impacts for eachmaterial topic.

2150

Guidance to 2-23-b-i

2151
2152

Human rights are rights inherent to all human beings and are all interrelated, interdependent, andindivisible.

2153
2154
2155
2156
2157
2158

The internationally recognized human rights include, at a minimum, the rights set out in the UN
International Bill of Human Rights [15] and the principles concerning fundamental rights set out in theInternational Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work[5]. The UN International Bill of Human Rights consists of the Universal Declaration of Human Rights,
the International Covenant on Economic, Social and Cultural Rights, and the International Covenant
on Civil and Political Rights and its two Optional Protocols.

2159
2160
2161
2162
2163

Other UN instruments elaborate further on the rights of indigenous peoples; women; national or
ethnic, religious and linguistic minorities; children; persons with disabilities; and migrant workers andtheir families. There are also standards of international humanitarian law that apply in situations ofarmed conflict, such as the International Committee of the Red Cross (ICRC) Geneva Conventions of1949 [1].2

2164
2165

At the regional level, binding treaties as well as non-binding instruments provide region-specificframeworks for human rights.3

2166
2167
2168
2169
2170
2171

If the policy commitment covers all internationally recognized human rights, a brief statement of thisfact is sufficient to comply with the requirement. The organization can also state if the policy
commitment references certain rights that require particular attention. For example, an organization
can state that its policy commitment covers all internationally recognized human rights, and also
references the rights to privacy and freedom of expression in particular, because the organization has
identified that its activities have an impact on these rights.

2172
2173
2174

If the policy commitment covers only some internationally recognized human rights, the organizationis required to state the rights that are covered. It can also explain why the policy commitment islimited to these rights.

2175

Guidance to 2-23-b-ii

2176
2177
2178

Categories of stakeholders that the organization gives particular attention to can include consumers,
customers, employees and other workers, and local communities. They can also include individuals
belonging to groups or populations that are considered to be at risk or vulnerable, such as children;

2 See the Office of the United Nations High Commissioner for Human Rights’ non-exhaustive list of universal

human rights instruments,
https://www.ohchr.org/EN/ProfessionalInterest/Pages/UniversalHumanRightsInstruments.aspx, accessed on 7
May 2021.
3 See the Office of the United Nations High Commissioner for Human Rights’ list of regional human rights

treaties, https://www.ohchr.org/en/issues/escr/pages/regionalhrtreaties.aspx, accessed on 7 May 2021.

Page 68 of 115

2179
2180
2181
2182

human rights defenders; indigenous peoples; 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; persons with disabilities; orwomen.

2183
2184
2185

For example, a bank may give particular attention in its policy commitment to avoid discriminating
against specific categories of customers, or a mining organization may give particular attention to
avoid infringing on the rights of indigenous peoples.

2186

Guidance to 2-23-d

2187
2188
2189

The most senior level may differ between organizations. For example, the most senior level in an
organization could be the highest governance body (e.g., the board), or it could be the most senior
executive (e.g., chief executive officer).

2190
2191

The organization can also report the dates of approval and adoption of the policy commitments, andhow frequently the commitments are reviewed.

2192

Guidance to 2-23-e

2193
2194

If the policy commitments apply to all of the organization’s activities and business relationships
equally, a brief statement of this fact is sufficient to comply with the requirement.

2195
2196
2197
2198

If the policy commitments apply to only some of the organization’s activities (e.g., they apply only toentities located in certain countries, or to certain subsidiaries), the organization should report which of
its activities the commitments apply to. It can also explain why the commitments are limited to these
activities.

2199
2200
2201
2202
2203
2204

If the policy commitments apply to only some of the organization’s business relationships, theorganization should specify the types of business relationships the commitments apply to (e.g.,
distributors, franchisees, joint ventures, suppliers). It can also explain why the commitments arelimited to these business relationships. The organization should also explain whether the business
relationships are obligated to abide by the policy commitments or are encouraged (but not obligated)to do so.

2205

Guidance to 2-23-f

2206

The organization can report:

2207
2208

•

whether the policy commitments need to be read, agreed to, and signed regularly by all
workers, business partners, and other relevant parties, such as governance body members;

2209
2210

•

the means through which it communicates the policy commitments (e.g., newsletters, formal
or informal meetings, dedicated websites, contractual agreements);

2211
2212

•

how it identifies and removes potential barriers to the communication or dissemination of thepolicy commitments (e.g., by making them accessible and available in relevant languages).

2213

Disclosure 2-24 Embedding policy commitments

2214

Requirements

2215

The organization shall:

2216
2217

a. describe how it embeds each of its policy commitments for responsible business conduct
throughout its activities and business relationships, including:

2218
2219

i.

how it allocates responsibility to implement the commitments across different
levels within the organization;

2220
2221

ii.

how it integrates the commitments into organizational strategies, operational
policies, and operational procedures;

2222

iii.

how it implements its commitments with and through its business relationships;

Page 69 of 115

2223

iv.

training that the organization provides on implementing the commitments.

2224

Guidance

2225
2226
2227
2228

This disclosure gives insight into how the organization embeds its policy commitments for responsible
business conduct, including the commitment to respect human rights, throughout its activities andbusiness relationships. This ensures that people at all levels act responsibly and with awareness ofand respect for human rights.

2229

Guidance to 2-24-a-i

2230
2231

Examples of different levels within an organization include the highest governance body, senior
executives, and operational levels.

2232

The organization can report:

2233
2234

•

the most senior level with oversight of, or accountability for, the implementation of the policy
commitments;

2235
2236
2237

•

the functions in the organization with day-to-day responsibility for implementing each of thepolicy commitments (e.g., human resources with the responsibility for implementing thecommitment to respect the rights of workers), including:

2238

-

their reporting lines to senior decision-making levels;

2239

-

the reason for allocating the responsibility to them;

2240
2241

•

whether responsible business conduct is formally discussed at meetings of the highest
governance body or senior executives and, if so, which topics are discussed;

2242
2243
2244

•

whether there are other formal or systematic means for discussions about responsible
business conduct between different levels or functions in the organization (e.g., a crossfunctional working group).

2245

Guidance to 2-24-a-ii

2246

The organization can describe:

2247

•

how it aligns the policy commitments with its:

2248

-

broader risk management systems and management policies;

2249
2250

-

economic, environmental, social, and human rights impact assessments, and other due
diligence processes;

2251
2252

-

policies and procedures that set financial and other performance incentives for
management or workers;

2253
2254

•

how it applies the policy commitments when making decisions, such as about its sourcing andoperating locations;

2255
2256
2257

•

the systems (e.g., internal audit) it uses to monitor compliance with the policy commitments
throughout its activities (across functions and geographic locations) and throughout its
business relationships.

2258

Guidance to 2-24-a-iii

2259

The organization can describe:

2260
2261

•

its procurement or investment policies and practices, and its engagement with those withwhich it has business relationships, including:

2262
2263
2264

-

whether and how it applies pre-qualification processes, bidding criteria, or screening
criteria consistent with the expectations stipulated in the policy commitments forresponsible business conduct;

2265
2266

-

whether and how it considers the policy commitments in contracting or investment
agreements, or in specific policies or codes of conduct for suppliers;

Page 70 of 115

-

2267
2268

whether and how it considers the policy commitments in the process of determining
whether to initiate, continue, or terminate a business relationship;

2269
2270

•

processes through which it enables or supports business partners and other parties toimplement the policy commitments (e.g., capacity building, peer sharing);

2271
2272

•

incentives that it offers to business partners and other parties to implement the policy
commitments (e.g., price premiums, increased orders, long-term contracts).

2273

Guidance to 2-24-a-iv

2274

The organization can report:

2275

•

the content of the training;

2276

•

to whom the training is provided, and whether it is mandatory;

2277

•

the form (e.g., in-person, online) and frequency of the training;

2278

•

examples of how the organization has determined that the training is effective.

2279
2280
2281

The organization can report whether the training covers how to implement the policy commitments ingeneral or in specific situations (e.g., ensuring the commitment toward privacy when handlingcustomers’ personal data, ensuring the policy commitments are considered in procurement practices).

2282
2283
2284
2285
2286
2287

The organization can specify if training is provided to those with day-to-day responsibility for andthose with oversight of, or accountability for, the implementation of the policy commitments. The
organization can also specify if training is provided to those with which it has business relationships(e.g., distributors, franchisees, joint ventures, suppliers). The organization can report the number orpercentage of workers, business partners, and other parties that have been trained during thereporting period.

2288

Disclosure 2-25 Processes to remediate negative impacts

2289

Requirements

2290

The organization shall:

2291
2292

a. describe its commitments to provide for or cooperate in the remediation of negative
impacts that the organization identifies it has caused or contributed to;

2293
2294

b. describe its approach to identify and address grievances, including the grievancemechanisms that the organization has established or participates in;

2295
2296

c. describe other processes by which the organization provides for or cooperates in theremediation of negative impacts that it identifies it has caused or contributed to;

2297
2298

d. describe how the stakeholders who are the intended users of the grievance mechanisms
are involved in the design, review, operation, and improvement of these mechanisms;

2299
2300
2301

e. describe how the organization tracks the effectiveness of the grievance mechanisms andother remediation processes, and report examples of their effectiveness, including
stakeholder feedback.

2302

Guidance

2303
2304
2305
2306
2307

This disclosure covers grievance mechanisms that the organization has established or participates in.
Grievance mechanisms enable stakeholders to raise concerns about, and seek remedy for, theorganization’s potential and actual negative impacts on them. This includes impacts on their humanrights. This disclosure also covers other processes by which the organization provides for orcooperates in the remediation of negative impacts that it identifies it has caused or contributed to.

2308
2309

The United Nations (UN) Guiding Principles on Business and Human Rights [14] and the Organisation
for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises [12] set

Page 71 of 115

2310
2311
2312
2313
2314
2315
2316

out expectations for organizations to provide for or cooperate in the remediation, through legitimate
processes, of negative impacts that they identify they have caused or contributed to. The organization
is not responsible for providing for, or cooperating in, the remediation of negative impacts that are
directly linked to its operations, products, or services by its business relationships, where theorganization has not contributed to the impacts. It can, however, play a role in doing so. See Box 3 in
GRI 3: Material Topics 2021 for more information on causing, contributing, or being directly linked tonegative impacts.

2317
2318

These instruments also set out expectations for organizations to establish or participate in effective
operational-level grievance mechanisms.

2319
2320
2321
2322

Grievance mechanisms are distinct from whistleblowing mechanisms. Whistleblowing mechanisms
enable individuals to raise concerns about wrongdoing or breaches of the law in the organization’s
operations or business relationships, regardless of whether the individuals themselves are harmed ornot. Whistleblowing mechanisms are reported under Disclosure 2-26 in this Standard.

2323
2324
2325

This disclosure covers the operation of grievance mechanisms and other remediation processes. The
actions taken to provide for or cooperate in the remediation of actual negative impacts for material
topics are reported under 3-3-d-ii in GRI 3.

2326
2327
2328
2329
2330

The disclosure is only relevant to environmental remediation processes (e.g., processes to remove
contaminants from soil) when these are connected to impacts on stakeholders or grievances raisedby stakeholders. However, the remedy provided to stakeholders through the mechanisms andprocesses covered by this disclosure may involve environmental remediation. The use ofenvironmental remediation processes can be reported under 3-3-d-ii in GRI 3.

2331

Guidance to 2-25-b

2332
2333

Grievance mechanisms refer to any routinized, state-based or non-state-based, judicial or non-judicial
processes through which stakeholders can raise grievances and seek remedy.

2334
2335
2336
2337

Examples of state-based judicial and non-judicial grievance mechanisms include courts (for both
criminal and civil actions), labor tribunals, national human rights institutions, National Contact Points
under the OECD Guidelines for Multinational Enterprises, ombudsperson offices, consumer protection
agencies, regulatory oversight bodies, and government-run complaints offices.

2338
2339
2340
2341
2342

Non-state-based grievance mechanisms include those administered by the organization, either alone
or together with stakeholders, such as operational-level grievance mechanisms and collective
bargaining, including the mechanisms established by collective bargaining. They also include
mechanisms administered by industry associations, international organizations, civil society
organizations, or multi-stakeholder groups.

2343
2344
2345
2346
2347

Operational-level grievance mechanisms are administered by the organization either alone or incollaboration with other parties and are directly accessible by the organization’s stakeholders. They
allow for grievances to be identified and addressed early and directly, thereby preventing both harmand grievances from escalating. They also provide important feedback on the effectiveness of theorganization’s due diligence from those who are directly affected.

2348

The organization can describe:

2349
2350
2351
2352
2353
2354

•

the intended purpose and users of the mechanisms (i.e., whether they are intended for aparticular stakeholder category, topic, or region) and whether they enable users to raisehuman rights-related concerns. For example, the organization can explain that it hasestablished a mechanism for community members to raise complaints about resettlement, as
well as a separate hotline for workers to raise concerns about issues affecting their rights,
such as health and safety conditions;

2355

•

how the mechanisms operate and who administers them (the organization or another party);

2356
2357
2358

•

whether operational-level grievance mechanisms are administered at the organizational level
or whether they are administered at a lower level (at the site or project level) and, in such acase, how information from these mechanisms is centralized;

2359
2360
2361

•

how the mechanisms have been designed and on which principles and guidelines they arebased, including whether they are designed to meet the effectiveness criteria set out in UN
Guiding Principle 31 [14];Page 72 of 115

2362

•

the process through which grievances are investigated;

2363

•

whether grievances are communicated to the highest governance body;

2364

•

whether grievances are treated confidentially;

2365
2366

•

whether the mechanisms can be used by stakeholders anonymously through representation
by a third party;

2367
2368

•

whether the organization requires or provides incentives for the creation or improvement ofoperational-level grievance mechanisms in workplaces of suppliers;

2369
2370
2371

•

whether the organization provides a back-up process for workplaces of suppliers that do nothave operational-level grievance mechanisms or where the existing grievance mechanisms inthose workplaces result in unresolved issues.

2372

Guidance to 2-25-c

2373
2374

Requirement 2-25-c covers remediation processes other than grievance mechanisms. Suchprocesses lead to the remediation of an impact without mechanisms for filing a formal complaint.

2375
2376

Examples include instances where the organization takes action to remediate an actual impact
evidenced in an impact assessment or a report published by a civil society organization.

2377

Guidance to 2-25-d

2378
2379
2380

The organization can describe, for example, how it engages with stakeholders who are the intended
users of the grievance mechanisms, to understand how they want to access the mechanisms to raise
concerns, and their expectations about how the mechanisms will operate.

2381

Guidance to 2-25-e

2382
2383
2384
2385
2386

According to UN Guiding Principle 31 [14], effective grievance mechanisms are legitimate, accessible,
predictable, equitable, transparent, rights-compatible, and a source of continuous learning. In addition
to these criteria, effective operational-level grievance mechanisms are also based on engagementand dialogue. It can be more difficult for the organization to assess the effectiveness of grievancemechanisms that it participates in compared to those it has established itself.

2387

The organization can report:

2388
2389

•

whether and how the intended users are informed about the grievance mechanisms andremediation processes;

2390
2391

•

whether and how the intended users are trained to use the grievance mechanisms andremediation processes;

2392
2393
2394

•

the accessibility of the grievance mechanisms and remediation processes, such as thenumber of hours per day or days per week they are accessible, and their availability indifferent languages;

2395
2396

•

how the organization seeks to ensure it respects users’ human rights and protects themagainst reprisals (i.e., non-retaliation for raising complaints or concerns);

2397
2398

•

how satisfied users are with the grievance mechanisms and remediation processes, and withthe resulting outcomes, as well as how the organization assesses user satisfaction;

2399
2400
2401

•

the number and types of grievances filed during the reporting period, and the percentage ofgrievances that were addressed and resolved, including the percentage that were resolved
through remediation;

2402

•

the number of grievances filed during the reporting period that are repeated or recurring;

2403
2404

•

changes made to the grievance mechanisms and remediation processes in response tolessons learned about their effectiveness.

2405
2406
2407
2408

Quantitative data, such as the number of grievances, is unlikely to be sufficient on its own. For
example, a low number of grievances could indicate that few incidents have occurred, but it could also
signal that the mechanisms are not trusted by their intended users. For this reason, contextual
information should be provided to help information users interpret the data.

Page 73 of 115

2410

Disclosure 2-26 Mechanisms for seeking advice and raisingconcerns

2411

Requirements

2412

The organization shall:

2413

a. describe the mechanisms for individuals to:

2409

2414
2415

i.

seek advice on implementing the organization’s policies and practices forresponsible business conduct;

2416

ii.

raise concerns about the organization’s business conduct.

2417

Guidance

2418
2419
2420
2421
2422

This disclosure covers the organization’s mechanisms for individuals to seek advice and to raise
concerns about responsible business conduct in the operations of the organization and its business
relationships. Examples of these mechanisms include confidential interviews during site visits,
escalation processes (to raise issues through management levels), hotlines, mechanisms to reportnon-compliance with laws and regulations, and whistleblowing mechanisms.

2423
2424
2425
2426
2427
2428

These mechanisms enable individuals to raise concerns about wrongdoing or breaches of the law inthe organization’s operations or business relationships, regardless of whether the individuals
themselves are harmed or not. They are distinct from grievance mechanisms, which enable
stakeholders to raise concerns about, and seek remedy for, the organization’s potential and actual
negative impacts on them. Grievance mechanisms are reported under Disclosure 2-25 in thisStandard.

2429
2430
2431
2432

If the organization’s grievance mechanisms and its mechanisms for seeking advice and raisingconcerns about responsible business conduct operate in a similar way, the organization can provide asingle description of how these mechanisms operate and explain which mechanisms the description
covers.

2433

The organization can report:

2434

•

who the intended users of the mechanisms are;

2435
2436

•

how the mechanisms operate and which level or function in the organization is assigned
responsibility for them;

2437
2438

•

whether the mechanisms are operated independently of the organization (e.g., by a third
party);

2439•

the process through which concerns are investigated;

2440

•

whether requests for advice and concerns raised are treated confidentially;

2441

•

whether the mechanisms can be used anonymously.

2442
2443

Additionally, the organization can report information about the effectiveness of the mechanisms,
including:

2444
2445

•

whether and how the intended users are informed about the mechanisms and trained on how
to use them;

2446
2447

•

the accessibility of the mechanisms, such as the number of hours per day or days per week
they are available, and their availability in different languages;

2448
2449

•

how the organization seeks to ensure it respects users’ human rights and protects themagainst reprisals (i.e., non-retaliation for raising concerns);

2450

•

how satisfied users are with the mechanisms and with the resulting outcomes;

Page 74 of 115

2451
2452

•

the number and types of requests for advice received during the reporting period, and thepercentage of requests that were answered;

2453
2454

•

the number and types of concerns raised during the reporting period, and the percentage ofconcerns that were addressed and resolved or found to be unsubstantiated.

2455

Disclosure 2-27 Compliance with laws and regulations

2456

Requirements

2457

The organization shall:

2458
2459

a. report the total number of significant instances of non-compliance with laws andregulations during the reporting period, and a breakdown of this total by:

2460

i.

instances for which fines were incurred;

2461

ii.

instances for which non-monetary sanctions were incurred;

2462
2463
2464

b. report the total number and the monetary value of fines for instances of non-compliancewith laws and regulations that were paid during the reporting period, and a breakdown of
this total by:

2465
2466

i.

fines for instances of non-compliance with laws and regulations that occurred in
the current reporting period;

2467
2468

ii.

fines for instances of non-compliance with laws and regulations that occurred inprevious reporting periods;

2469

c. describe the significant instances of non-compliance;

2470

d. describe how it has determined significant instances of non-compliance.

2471

Guidance

2472
2473

This disclosure addresses non-compliance, or failure to comply with, laws and regulations that are
applicable to the organization.

2474
2475

Non-compliance with laws and regulations can give insight into the ability of management to ensurethat the organization conforms to certain performance parameters.

2476
2477

Laws and regulations can be issued by a variety of bodies including local, regional, and national
governments; regulatory authorities; and public agencies.

2478

Laws and regulations include:

2479

•

international declarations, conventions, and treaties;

2480

•

national, subnational, regional, and local regulations;

2481
2482

•

binding voluntary agreements made with regulatory authorities and developed as a substitutefor implementing a new regulation;

2483
2484
2485

•

voluntary agreements (or covenants), if the organization directly joins the agreement, or if
public agencies make the agreement applicable to organizations in their territory throughlegislation or regulation.

2486
2487

This disclosure includes significant instances of non-compliance that resulted in administrative or
judicial sanctions as well as fines that are being appealed during the reporting period.

2488
2489
2490
2491

Non-monetary sanctions can include restrictions imposed by governments, regulatory authorities, or
public agencies on the organization’s activities or operations, such as withdrawal of trading licenses
or licenses to operate in highly regulated industries. They can also include directives to cease or
remediate an unlawful activity.

Page 75 of 115

2492
2493
2494

The organization can use information about fines that have been reported in its audited consolidated
financial statements or in the financial information filed on public record, including fines that are being
appealed and which may appear as balance sheet reserves in the financial statements.

2495
2496
2497

If there were no significant instances of non-compliance with laws and regulations or no fines were
paid during the reporting period, a brief statement of this fact is sufficient to comply with thedisclosure.

2498

Guidance to 2-27-c

2499
2500
2501
2502

The description of significant instances of non-compliance can include the geographic location where
the instance occurred, and the matter to which the instance relates, such as a tax fraud or a spill. The
organization is required to report sufficient information for information users to understand the type
and the context of significant instances of non-compliance.

2503

The organization can also explain whether the significant instances are repeated or recurring.

2504

Guidance to 2-27-d

2505

When determining the significant instances of non-compliance, the organization can assess:

2506

•

the severity of the impact resulting from the instance;

2507

•

external benchmarks used in its sector to determine significant instances of non-compliance.

2508

Disclosure 2-28 Membership associations

2509

Requirements

2510

The organization shall:

2511
2512

a. report industry associations, other membership associations, and national or international
advocacy organizations in which it participates in a significant role.

2513

Guidance

2514
2515
2516
2517
2518

The organization may have a significant role in an association or advocacy organization when it holds
a position in the governance body, participates in projects or committees, or provides substantive
funding beyond routine membership dues. The role may also be significant when the organization
views its membership as strategic to influencing the mission or objective of the association that is
critical to the organization’s own activities.

Page 76 of 115

2519

5. Stakeholder engagement

2520
2521

The disclosures in this section provide information about the organization’s stakeholder engagement
practices, including how it engages in collective bargaining with employees.

2522

Disclosure 2-29 Approach to stakeholder engagement

2523

Requirements

2524

The organization shall:

2525

a. describe its approach to engaging with stakeholders, including:

2526

i.

the categories of stakeholders it engages with, and how they are identified;

2527

ii.

the purpose of the stakeholder engagement;

2528

iii.

how the organization seeks to ensure meaningful engagement with stakeholders.

2529

Guidance

2530
2531
2532

Stakeholders are individuals or groups that have interests that are affected or could be affected by theorganization’s activities [11]. For more information on stakeholders, see section 2.4 in GRI 1:
Foundation 2021.

2533
2534

This disclosure covers stakeholder engagement undertaken by the organization as part of its ongoing
activities, rather than specifically for the purpose of sustainability reporting.

2535

Guidance to 2-29-a-i

2536
2537
2538
2539

Common categories of stakeholders for organizations are business partners, civil society
organizations, consumers, customers, employees and other workers, governments, local
communities, non-governmental organizations, shareholders and other investors, suppliers, tradeunions, and vulnerable groups.

2540
2541

The organization can explain how it determines which categories of stakeholders to engage with andwhich categories not to engage with.

2542

Guidance to 2-29-a-ii

2543
2544
2545
2546

The purpose of stakeholder engagement can be, for example, to identify actual and potential impacts
or to determine prevention and mitigation responses to potential negative impacts. In some cases,
stakeholder engagement is a right in and of itself, such as the right of workers to form or join tradeunions or their right to bargain collectively.

2547

The organization can also report:

2548
2549

•

the type of stakeholder engagement (e.g., participation, consultation, information) and its
frequency (e.g., ongoing, quarterly, annually);

2550
2551
2552

•

when it engages directly with stakeholders and when it engages with credible stakeholder
representatives or proxy organizations, or other credible independent expert resources, and
why;

2553
2554
2555

•

whether stakeholder engagement activities take place at the organizational level or at a lower
level, such as at the site or project level, and in the latter case, how information fromstakeholder engagement activities is centralized;

2556

•

the resources (e.g., financial or human resources) allocated to stakeholder engagement.

2557
2558

Further information on stakeholder engagement undertaken for specific activities is reported underother disclosures. For example, the organization is required to report on stakeholder engagement

Page 77 of 115

2559
2560

undertaken for determining and managing material topics under 3-1-b and 3-3-f in GRI 3: Material
Topics 2021.

2561

Guidance to 2-29-a-iii

2562
2563
2564

Meaningful stakeholder engagement is characterized by two-way communication and depends on thegood faith of participants on both sides. It is also responsive and ongoing and includes in many cases
engaging with relevant stakeholders before decisions are made. [11]2565

The organization can report:

2566
2567

•

how it takes into account potential barriers to stakeholder engagement (e.g., language andcultural differences, gender and power imbalances, divisions within a community or group);

2568
2569

•

how it engages with at-risk or vulnerable groups (e.g., whether it takes specific approaches
and gives special attention to potential barriers);

2570
2571

•

how it provides stakeholders with information that is understandable and accessible throughappropriate communication channels;

2572
2573

•

how stakeholder feedback is recorded and integrated into decision-making, and how
stakeholders are informed about the way in which their feedback has influenced decisions;

2574
2575

•

how it seeks to respect the human rights of all stakeholders engaged, for example, their rights
to privacy, freedom of expression, and peaceful assembly and protest;

2576
2577
2578

•

how it works with business partners to engage with stakeholders in a meaningful way,
including the expectations it places on business partners to respect the human rights ofstakeholders during engagement.

2579

Disclosure 2-30 Collective bargaining agreements

2580

Requirements

2581

The organization shall:

2582

a. report the percentage of total employees covered by collective bargaining agreements;

2583
2584
2585
2586

b. for employees not covered by collective bargaining agreements, report whether theorganization determines their working conditions and terms of employment based oncollective bargaining agreements that cover its other employees or based on collective
bargaining agreements from other organizations.

2587

Guidance

2588
2589
2590

This disclosure provides insights into how the organization engages in collective bargaining with its
employees. The right to collective bargaining is a fundamental right at work that is covered in theInternational Labour Organization (ILO) Right to Organise and Collective Bargaining Convention [8].

2591
2592
2593
2594
2595
2596

Collective bargaining refers to negotiations that take place between one or more employers or
employers' organizations and one or more workers' organizations (e.g., trade unions). The objective of
these negotiations is to reach a collective agreement on working conditions and terms of employment(e.g., wages, working time) and to regulate relations between employers and workers. [3] These
negotiations are an important means through which employers’ organizations and workers’organizations can improve working conditions and labor relations.

2597
2598
2599
2600

Collective agreements can be made at the level of the organization, at the level of a particular site, atthe industry level, and at the national level in countries where this is the practice. Collective
agreements can cover specific groups of workers, for example, those performing a specific activity or
working at a specific location.

2601
2602

If the organization has a statement or policy commitment on freedom of association and collective
bargaining, this is reported under 2-23-b-i in this Standard or 3-3-c in GRI 3: Material Topics 2021.

Page 78 of 115

2603

See references [2], [3], [4], [5], [6], [8], [10], [21], [25], and [26] in the Bibliography.

2604

Guidance to 2-30-a

2605
2606

The organization is required to report the percentage of its employees whose working conditions andterms of employment are regulated by one or more collective bargaining agreements.

2607
2608

The percentage of employees covered by collective bargaining agreements is calculated using thefollowing formula:

2609

Number of employees covered by collective bargaining agreements
× 100
Total number of employees reported under 2-7-a

2610
2611
2612
2613

The employees covered by collective bargaining agreements are those employees to whom theorganization is obligated to apply the agreement. This means that if none of the employees is coveredby a collective bargaining agreement, the percentage reported is zero. An employee covered by morethan one collective bargaining agreement only needs to be counted once.

2614
2615
2616
2617
2618
2619
2620
2621

This requirement does not ask for the percentage of employees represented by a works council or
belonging to trade unions, which can be different. The percentage of employees covered by collective
bargaining agreements can be higher than the percentage of unionized employees when thecollective bargaining agreements apply to both union and non-union members. Alternatively, thepercentage of employees covered by collective bargaining agreements can be lower than thepercentage of unionized employees. This may be the case when there are no collective bargaining
agreements available or when the collective bargaining agreements do not cover all unionizedemployees.

2622
2623

The organization can also provide a breakdown of the percentage of employees covered by collective
bargaining agreements by region, or provide comparisons with industry benchmarks.

2624

Guidance to 2-30-b

2625
2626
2627
2628
2629
2630
2631
2632

There may be instances where some or none of the organization’s employees are covered bycollective bargaining agreements. However, the working conditions and terms of employment of these
employees may be influenced or determined by the organization based on other collective bargaining
agreements, such as agreements that cover other employees or agreements from otherorganizations. If this is the case, the organization is required to report it under 2-30-b. If this is not thecase, and the working conditions and terms of employment of these employees are not influenced ordetermined based on other collective bargaining agreements, a brief statement of this fact is sufficient
to comply with this requirement.

Page 79 of 115

2633

Glossary

2634
2635

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

2636
2637
2638

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.

2639

business partner

2640
2641

entity with which the organization has some form of direct and formal engagement for the purpose of
meeting its business objectives

2642

Source: Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015; modified

2643
2644

Examples: affiliates, business-to-business customers, clients, first-tier suppliers, franchisees, joint
venture partners, investee companies in which the organization has a shareholding position2645

Note: Business partners do not include subsidiaries and affiliates that the organization controls.

2646

business relationships

2647
2648
2649

relationships that the organization has with business partners, with entities in its value chain including
those beyond the first tier, and with any other entities directly linked to its operations, products, orservices

2650
2651

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

2652
2653
2654

Note: Examples of other entities directly linked to the organization’s operations, products, or services
are a non-governmental organization with which the organization delivers support to a local
community, or state security forces that protect the organization’s facilities.

2655

collective bargaining

2656
2657
2658
2659

all negotiations that take place between one or more employers or employers' organizations, on the
one hand, and one or more workers' organizations (trade unions), on the other, for determining
working conditions and terms of employment or for regulating relations between employers andworkers

2660
2661

Source: International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154);
modified2662

conflict of interest

2663
2664

situation where an individual is confronted with choosing between the requirements of their function in
the organization and their other personal or professional interests or responsibilities

2665

due diligence

2666
2667

process to identify, prevent, mitigate, and account for how the organization addresses its actual andpotential negative impacts

2668
2669
2670

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; and Organisation for Economic Cooperation and Development (OECD), OECD Guidelines for Multinational Enterprises, 2011; modified

2671

Note: See section 2.3 in GRI 1: Foundation 2021 for more information on ‘due diligence’.

2672

employee

2673
2674

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

Page 80 of 115

2675

full-time employee

2676
2677

employee whose working hours per week, month, or year are defined according to national law orpractice regarding working time

2678

governance body

2679
2680
2681

formalized group of individuals responsible for the strategic guidance of the organization, the effective
monitoring of management, and the accountability of management to the broader organization and its
stakeholders

2682

grievance

2683
2684
2685

perceived injustice evoking an individual’s or a group’s sense of entitlement, which may be based onlaw, contract, explicit or implicit promises, customary practice, or general notions of fairness ofaggrieved communities

2686
2687

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011

2688

grievance mechanism

2689

routinized process through which grievances can be raised and remedy can be sought

2690
2691

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

2692
2693

Note: See Guidance to Disclosure 2-25 in GRI 2: General Disclosures 2021 for more information on‘grievance mechanism’.

2694

highest governance body2695

governance body with the highest authority in the organization

2696
2697
2698
2699

Note: In some jurisdictions, governance systems consist of two tiers, where supervision andmanagement are separated or where local law provides for a supervisory board drawn from nonexecutives to oversee an executive management board. In such cases, both tiers are included under
the definition of highest governance body.

2700

human rights

2701
2702
2703
2704

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

2705
2706

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

2707
2708

Note: See Guidance to 2-23-b-i in GRI 2: General Disclosures 2021 for more information on ‘humanrights’.

2709

impact

2710
2711
2712

effect 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

2713
2714

Note 1: Impacts can be actual or potential, negative or positive, short-term or long-term, intended orunintended, and reversible or irreversible.

2715

Note 2: See section 2.1 in GRI 1: Foundation 2021 for more information on ‘impact’.

Page 81 of 115

2716

local community

2717
2718

individuals or groups of individuals living or working in areas that are affected or that could be affectedby the organization’s activities

2719
2720

Note: The local community can range from those living adjacent to the organization’s operations tothose living at a distance.

2721

material topics

2722
2723

topics that represent the organization’s most significant impacts on the economy, environment, andpeople, including impacts on their human rights

2724
2725

Note: See section 2.2 in GRI 1: Foundation 2021 and section 1 in GRI 3: Material Topics 2021 formore information on ‘material topics’.

2726

mitigation

2727

action(s) taken to reduce the extent of a negative impact

2728
2729
2730
2731

Note: The mitigation of an actual negative impact refers to actions taken to reduce the severity of thenegative impact that has occurred, with any residual impact needing remediation. The mitigation of apotential negative impact refers to actions taken to reduce the likelihood of the negative impact
occurring.

2732
2733

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; modified

2734

non-guaranteed hours employee

2735
2736

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

2737

Examples: casual employees, employees with zero-hour contracts, on-call employees

2738

Source: ShareAction, Workforce Disclosure Initiative Survey Guidance Document, 2020; modified

2739

part-time employee

2740
2741

employee whose working hours per week, month, or year are less than the number of working hours
for full-time employees

2742

permanent employee

2743
2744

employee with a contract for an indeterminate period (i.e., indefinite contract) for full-time or part-time
work

2745

remedy / remediation

2746

means to counteract or make good a negative impact / provision of remedy

2747
2748
2749

Examples: apologies, restitution, restoration, rehabilitation, financial or non-financial compensation,and punitive sanctions (whether criminal or administrative, such as fines), prevention of harm throughinjunctions or guarantees of non-repetition

2750
2751

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; modified

2752

reporting period2753

specific time period covered by the reported information

2754

Examples: fiscal year, calendar year2755

senior executive

2756
2757

high-ranking member of the management of the organization, such as the Chief Executive Officer(CEO) or an individual reporting directly to the CEO or the highest governance body

Page 82 of 115

2758

severity (of an impact)

2759
2760
2761

The severity of an actual or potential negative impact is determined by its scale (i.e., how grave theimpact is), scope (i.e., how widespread the impact is), and irremediable character (how hard it is tocounteract or make good the resulting harm).

2762
2763
2764

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; and the Organisation for Economic Co-operation and Development (OECD), OECD Due
Diligence Guidance for Responsible Business Conduct, 2018; modified

2765

Note: See section 1 in GRI 3: Material Topics 2021 for more information on ‘severity’.

2766

stakeholder

2767
2768

individual or group that has an interest that is affected or could be affected by the organization’s
activities

2769
2770

Source: Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018; modified

2771
2772
2773

Examples: business partners, civil society organizations, consumers, customers, employees andother workers, governments, local communities, non-governmental organizations, shareholders andother investors, suppliers, trade unions, vulnerable groups

2774

Note: See section 2.4 in GRI 1: Foundation 2021 for more information on ‘stakeholder’.

2775

supplier

2776
2777

entity upstream from the organization (i.e., in the organization’s supply chain), which provides a
product or service that is used in the development of the organization’s own products or services

2778
2779

Examples: brokers, consultants, contractors, distributors, franchisees, home workers, independent
contractors, licensees, manufacturers, primary producers, sub-contractors, wholesalers

2780
2781

Note: A supplier can have a direct business relationship with the organization (often referred to as
first-tier supplier) or an indirect business relationship.

2782

supply chain

2783
2784

range of activities carried out by entities upstream from the organization, which provide products orservices that are used in the development of the organization’s own products or services

2785

sustainable development / sustainability

2786
2787

development that meets the needs of the present without compromising the ability of future
generations to meet their own needs

2788

Source: World Commission on Environment and Development, Our Common Future, 1987

2789
2790

Note: In the GRI Standards, the terms ‘sustainability’ and ‘sustainable development’ are usedinterchangeably.

2791

temporary employee

2792
2793
2794

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)

2795

under-represented social group

2796
2797
2798

group of individuals who are less represented within a subset (e.g., a body or committee, employeesof an organization) relative to their numbers in the general population, and who therefore have less
opportunity to express their economic, social, or political needs and views

2799

Note 1: Under-represented social groups may include minority groups.

2800
2801

Note 2: The groups included under this definition depend on the organization’s operating context andare not uniform for every organization.

Page 83 of 115

2802

value chain

2803
2804

range of activities carried out by the organization, and by entities upstream and downstream from theorganization, to bring the organization’s products or services from their conception to their end use

2805
2806
2807

Note 1: Entities upstream from the organization (e.g., suppliers) provide products or services that areused in the development of the organization’s own products or services. Entities downstream from theorganization (e.g., distributors, customers) receive products or services from the organization.

2808

Note 2: The value chain includes the supply chain.

2809

vulnerable group

2810
2811
2812

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

2813
2814
2815
2816
2817
2818

Examples: children and youth; elderly persons; ex-combatants; HIV/AIDS-affected households;
human rights defenders; indigenous peoples; internally displaced persons; migrant workers and theirfamilies; national or ethnic, religious and linguistic minorities; persons who might be discriminatedagainst based on their sexual orientation, gender identity, gender expression, or sex characteristics(e.g., lesbian, gay, bisexual, transgender, intersex); persons with disabilities; refugees or returning
refugees; women

2819

Note: Vulnerabilities and impacts can differ by gender.

2820

worker2821

person that performs work for the organization

2822
2823

Examples: employees, apprentices, interns, self-employed persons, and persons working fororganizations other than the reporting organization, such as for suppliers

2824
2825

Note: In the GRI Standards, in some cases it is specified whether a particular subset of workers is
required to be used.

Page 84 of 115

2826

Bibliography

2827
2828

This section lists authoritative intergovernmental instruments and additional references used indeveloping this Standard, as well as resources that can be consulted by the organization.

2829

Authoritative instruments:

2830
2831

1. International Committee of the Red Cross (ICRC), the Geneva Conventions of 1949 and theirAdditional Protocols, 1949.

2832

2. International Labour Organization (ILO), Collective Agreements Recommendation, 1951 (No. 91).

2833

3. International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

2834

4. International Labour Organization (ILO), Collective Bargaining Recommendation, 1981 (No. 163).

2835
2836

5. International Labour Organization (ILO), Declaration on Fundamental Principles and Rights at
Work, 1998.

2837
2838

6. International Labour Organization (ILO), Freedom of Association and Protection of the Right toOrganise Convention, 1948 (No. 87).

2839
2840

7. International Labour Organization (ILO), Resolution concerning the International Classification of
Status in Employment (ICSE), 1993.

2841
2842

8. International Labour Organization (ILO), Right to Organise and Collective Bargaining Convention,
1949 (No. 98).

2843
2844

9. International Labour Organization (ILO), Tripartite Declaration of Principles concerning
Multinational Enterprises and Social Policy, 2017.

2845

10. International Labour Organization (ILO), Workers’ Representatives Convention, 1971 (No. 135).

2846
2847

11. Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018.

2848
2849

12. Organisation for Economic Co-operation and Development (OECD), OECD Guidelines forMultinational Enterprises, 2011.

2850
2851

13. Organisation for Economic Co-operation and Development (OECD), OECD Principles ofCorporate Governance, 2004.

2852
2853

14. United Nations (UN), Guiding Principles on Business and Human Rights: Implementing the United
Nations “Protect, Respect and Remedy” Framework, 2011.

2854

15. United Nations (UN), International Bill of Human Rights:

2855

15.1 United Nations (UN), Universal Declaration of Human Rights, 1948.

2856

15.2 United Nations (UN), International Covenant on Civil and Political Rights, 1966.

2857
2858

15.3 United Nations (UN), International Covenant on Economic, Social, and Cultural Rights,
1966.

2859
2860

15.4 United Nations (UN), Optional Protocol to the International Covenant on Civil andPolitical Rights, 1966.

2861
2862

15.5 United Nations (UN), Second Optional Protocol to the International Covenant on Civil
and Political Rights, aiming at the abolition of the death penalty, 1989.

2863
2864

16. United Nations (UN), Protect, Respect and Remedy: a Framework for Business and Human
Rights, 2008.

2865
2866
2867

17. United Nations (UN), Report of the Special Representative of the Secretary-General on the Issueof Human Rights and Transnational Corporations and Other Business Enterprises, John Ruggie,
2011.

2868

18. United Nations (UN), Rio Declaration on Environment and Development, 1992.

Page 85 of 115

2869

Additional references:

2870
2871

19. Committee on Workers’ Capital (CWC), Guidelines for the Evaluation of Workers’ Human Rights
and Labour Standards, 2017.

2872

20. International Corporate Governance Network (ICGN), ICGN Global Governance Principles, 2017.

2873
2874
2875

21. International Labour Organization (ILO), 8.Freedom of Association and Collective Bargaining,https://www.ilo.org/global/topics/dw4sd/themes/freedom-of-association/lang--en/index.htm,
accessed on 7 May 2021.

2876
2877

22. International Labour Organization (ILO), ILOSTAT, https://ilostat.ilo.org/, accessed on 7 May
2021.

2878
2879

23. International Labour Organization (ILO), Key Indicators of the Labour Market (KILM), 9th ed.,
2016.

2880
2881

24. International Labour Organization (ILO), Non-standard employment around the world:
Understanding challenges, shaping prospects, 2016.

2882
2883
2884
2885

25. J. Visser, S. Hayter, and R. Gammarano, ‘Trends in collective bargaining coverage: stability,
erosion or decline?’, Issue Brief no. 1 – Labour Relations and Collective Bargaining, February
2017, https://www.ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/--travail/documents/publication/wcms_409422.pdf, accessed on 7 May 2021.

2886

26. ShareAction, The Workforce Disclosure Initiative 2020 Survey Guidance Document, 2020.

2887

Resources:

2888
2889
2890

27. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
Human Rights (OHCHR), and United Nations (UN) Global Compact, Human Rights Translated
2.0: A Business Reference Guide, 2017.

2891

28. Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015.

2892
2893

29. Shift, Oxfam, and Global Compact Network Netherlands, Doing Business with Respect for Human
Rights: A Guidance Tool for Companies, 2016.

2894
2895

30. United Nations (UN), Methodology. Standard country or area codes for statistical use (M49),
http://unstats.un.org/unsd/methods/m49/m49regin.htm, accessed on 7 May 2021.

2896
2897

31. United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012.

2898
2899

32. World Benchmarking Alliance (WBA), Corporate Human Rights Benchmark methodology,
updated periodically.

Page 86 of 115

2900

GRI 3: Material Topics 2021

2901

EFFECTIVE DATE: 1 JANUARY 2023

2902

UNIVERSAL STANDARD

Page 87 of 115

2903

GRI 3: Material Topics 2021

2904

Universal Standard

2905

Effective date

2906
2907

This Standard is effective for reports or other materials published on or after 1 January 2023. Earlier
adoption is encouraged.

2908

Responsibility

2909
2910

This Standard is issued by the Global Sustainability Standards Board (GSSB). Any feedback on the
GRI Standards can be submitted to ???@globalreporting.org for the consideration of the GSSB.

2911

Legal liability

2912
2913
2914
2915
2916
2917
2918
2919
2920
2921

This document, designed to promote sustainability reporting, has been developed by the Global
Sustainability Standards Board (GSSB) through a unique multi-stakeholder consultative process
involving representatives from organizations and report information users from around the world.
While the GRI Board of Directors and GSSB encourage use of the GRI Sustainability ReportingStandards (GRI Standards) and related Interpretations by all organizations, the preparation andpublication of reports based fully or partially on the GRI Standards and related Interpretations are thefull responsibility of those producing them. Neither the GRI Board of Directors, GSSB nor Stichting
Global Reporting Initiative (GRI) can assume responsibility for any consequences or damages
resulting directly or indirectly from the use of the GRI Standards and related Interpretations in the
preparation of reports, or the use of reports based on the GRI Standards and related Interpretations.

2922

Copyright and trademark notice

2923
2924
2925
2926
2927
2928

This document is copyright-protected by Stichting Global Reporting Initiative (GRI). The reproduction
and distribution of this document for information and/or use in preparing a sustainability report ispermitted without prior permission from GRI. However, neither this document nor any extract from it
may be reproduced, stored, translated, or transferred in any form or by any means (electronic,
mechanical, photocopied, recorded, or otherwise) for any other purpose without prior written
permission from GRI.

2929
2930

Global Reporting Initiative, GRI and logo, GSSB and logo, and GRI Sustainability ReportingStandards (GRI Standards) and logo are trademarks of Stichting Global Reporting Initiative.

2931© 2021 GRI. All rights reserved.

2932

ISBN 978-90-8866-NNN-N

Page 88 of 115

2933

Contents

2934

Introduction ........................................................................................................................................... 902935

1. Guidance to determining material topics........................................................................................... 93

2936

Step 1. Understand the organization’s context .............................................................................. 94

2937

Step 2. Identify actual and potential impacts ................................................................................. 96

2938

Step 3. Assess the significance of the impacts ............................................................................. 98

2939

Step 4. Prioritize the most significant impacts for reporting ........................................................ 100

2940

2. Disclosures on material topics ........................................................................................................ 102

2941

Disclosure 3-1 Process to determine material topics .................................................................. 102

2942

Disclosure 3-2 List of material topics ........................................................................................... 104

2943

Disclosure 3-3 Management of material topics ........................................................................... 105

2944

Glossary .............................................................................................................................................. 111

2945

Bibliography ........................................................................................................................................ 115

Page 89 of 115

2946

Introduction

2947
2948
2949
2950

GRI 3: Material Topics 2021 provides step-by-step guidance for organizations on how to determinematerial topics. It also explains how the Sector Standards are used in this process. Material topics are
topics that represent an organization’s most significant impacts on the economy, environment, andpeople, including impacts on their human rights.

2951
2952
2953

GRI 3 also contains disclosures for organizations to report information about their process ofdetermining material topics, their list of material topics, and how they manage each of their material
topics.

2954

The Standard is structured as follows:

2955

•

Section 1 provides step-by-step guidance on how to determine material topics.

2956
2957
2958

•

Section 2 contains three disclosures, which provide information about the organization’s
process of determining material topics, its list of material topics, and how it manages each
topic.

2959
2960

•

The Glossary contains defined terms with a specific meaning when used in the GRI
Standards.

2961
2962
2963

•

The Bibliography lists authoritative intergovernmental instruments and additional referencesused in developing this Standard, as well as resources that can be consulted by theorganization.

2964
2965

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

2966

System of GRI Standards

2967
2968
2969
2970

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.

2971
2972
2973

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).

2974

Universal Standards: GRI 1, GRI 2 and GRI 3

2975
2976
2977

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.

2978
2979
2980

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.

2981
2982
2983

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.

Page 90 of 115

2984

Sector Standards

2985
2986
2987

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.

2988

Topic Standards

2989
2990
2991

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.

2992

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

2993

Using this Standard

2994
2995
2996

An organization reporting in accordance with the GRI Standards is required to determine its material
topics and report all disclosures in this Standard. The organization is required to report Disclosure 3-3
Management of material topics for each material topic.

2997

Reasons for omission are only permitted for Disclosure 3-3.

2998
2999
3000
3001
3002

If the organization cannot comply with Disclosure 3-3 or with a requirement in Disclosure 3-3 (e.g.,
because the required information is confidential or subject to legal prohibitions), the organization isrequired to specify this in the GRI content index, and provide a reason for omission and an
explanation. See Requirement 6 in GRI 1: Foundation 2021 for more information on reasons foromission.

3003
3004

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 thePage 91 of 115

3005
3006
3007

requirement 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.

3008
3009
3010
3011
3012

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).

3013

Requirements, guidance and defined terms

3014

The following apply throughout the GRI Standards:

3015
3016

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.

3017

Requirements may be accompanied by guidance.

3018
3019

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

3020
3021

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

3022

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

3023
3024

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.

Page 92 of 115

3025

1. Guidance to determine material

3026

topics

3027
3028
3029

An organization reporting in accordance with the GRI Standards is required to determine its material
topics. When doing this, the organization is also required to use the applicable GRI Sector Standards(see Requirement 3 in GRI 1: Foundation 2021 and Box 5 in this Standard).

3030
3031
3032
3033

This section describes the four steps that the organization should follow in determining its material
topics (see Figure 2). Following the steps in this section helps the organization determine its material
topics and report the disclosures in section 2 of this Standard. The steps provide guidance and are
not requirements on their own.

3034

Figure 2. Process to determine material topics

3035
3036
3037
3038
3039
3040
3041

The first three steps in the process to determine material topics relate to the organization’s ongoing
identification and assessment of impacts. During these steps, the organization identifies andassesses its impacts regularly, as part of its day-to-day activities, and while engaging with relevant
stakeholders and experts. These ongoing steps allow the organization to actively identify and manage
its impacts as they evolve, and as new ones arise. The first three steps are conducted independentlyof the sustainability reporting process, but they inform the last step. In Step 4, the organization
prioritizes its most significant impacts for reporting and in this way determines its material topics.

3042
3043
3044
3045

In each reporting period, the organization should review its material topics from the previous reporting
period to account for changes in the impacts. Changes in impacts can result from changes in theorganization’s activities and business relationships. This review helps ensure the material topics
represent the organization’s most significant impacts in each new reporting period.

3046
3047

The organization should document its process of determining material topics. This includes
documenting the approach taken, decisions, assumptions, and subjective judgements made, sources

Page 93 of 115

3048
3049
3050

analyzed, and evidence gathered. Accurate records help the organization explain its chosen approachand report the disclosures in section 2 of this Standard. The records facilitate analysis and assurance.
See the Verifiability principle in GRI 1 for more information.

3051
3052
3053
3054
3055
3056

The approach for each step will vary according to the specific circumstances of the organization, suchas its business model; sectors; geographic, cultural, and legal operating context; ownership structure;and the nature of its impacts. Given these specific circumstances, the steps should be systematic,
documented, replicable, and used consistently in each reporting period. The organization should
document any changes in its approach together with the rationale for those changes and theirimplications.

3057
3058
3059

The organization’s highest governance body should oversee the process and review and approve thematerial topics. If the organization does not have a highest governance body, a senior executive orgroup of senior executives should oversee the process and review and approve the material topics.

3060

Box 1. Input to financial and value creation reporting

3061
3062
3063
3064

The material topics and impacts that have been determined through this process inform financial andvalue creation reporting. They provide crucial input for identifying financial risks and opportunities
related to the organization’s impacts, and for financial valuation. This in turn helps in making financial
materiality judgments about what to recognize in financial statements.

3065
3066
3067
3068
3069
3070

While most, if not all, of the impacts that have been identified through this process will eventually
become financially material, sustainability reporting is also highly relevant in its own right as a public
interest activity and is independent of the consideration of financial implications. It is therefore
important for the organization to report on all the material topics that it has determined using the GRI
Standards. These material topics cannot be deprioritized on the basis of not being consideredfinancially material by the organization.

3071
3072

See Box 1 in GRI 1: Foundation 2021 for more information on sustainability reporting and financial
and value creation reporting.

3073

The next sections describe the four steps to determine material topics in more detail.

3074

Step 1. Understand the organization’s context

3075
3076
3077
3078

In this step, the organization creates an initial high-level overview of its activities and business
relationships, the sustainability context in which these take place, as well as an overview of its
stakeholders. This provides the organization with critical information for identifying its actual andpotential impacts.

3079
3080
3081

The organization should consider the activities, business relationships, stakeholders, andsustainability context of all the entities it controls or has an interest in (e.g., subsidiaries, joint
ventures, affiliates), including minority interests.

3082
3083
3084
3085

Relevant departments and functions within the organization that can assist in this step include
communications, human resources, investor relations, legal and compliance department or functions,marketing and sales, procurement, and product development. The GRI Sector Standards describe thesectors’ context and they can also assist in this step.

3086

Activities

3087

The organization should consider the following in relation to its activities:

3088

•

The organization’s purpose, value or mission statements, business model, and strategies.

3089
3090

•

The types of activities it carries out (e.g., sales, marketing, manufacturing, distribution) andthe geographic locations of these activities.

3091
3092
3093

•

The types of products and services it offers and the markets it serves (i.e., the types ofcustomers and beneficiaries targeted, and the geographic locations where products andservices are offered).

Page 94 of 115

3094
3095

•

The sectors in which the organization is active and their characteristics (e.g., whether they
involve informal work, whether they are labor or resource intensive).

3096
3097
3098

•

The number of employees, including whether they are full-time, part-time, non-guaranteed
hours, permanent or temporary, and their demographic characteristics (e.g., age, gender,
geographic location).

3099
3100
3101
3102
3103

•

The number of workers who are not employees and whose work is controlled by theorganization, including the types of worker (e.g., agency workers, contractors, self-employedpersons, volunteers), their contractual relationship with the organization (i.e., whether theorganization engages these workers directly or indirectly through a third party), and the work
they perform.

3104

Business relationships

3105
3106
3107
3108

The organization’s business relationships include relationships with business partners, entities in its
value chain (including entities beyond the first tier), and any other entities directly linked to its
operations, products, or services. The organization should consider the following in relation to its
business relationships:

3109

•

The types of business relationships it has (e.g., joint ventures, suppliers, franchisees).

3110
3111

•

The types of activities undertaken by those with which it has business relationships (e.g.,
manufacturing the organization’s products, providing security services to the organization).

3112
3113

•

The nature of the business relationships (e.g., whether they are based on a long-term or
short-term contract, whether they are based on a specific project or event).

3114

•

The geographic locations where the activities of the business relationships take place.

3115

Sustainability context

3116
3117

The organization should consider the following to understand the sustainability context of its activities
and business relationships:

3118
3119
3120
3121

•

Economic, environmental, human rights, and other societal challenges at local, regional, andglobal levels related to the organization’s sectors and the geographic location of its activities
and business relationships (e.g., climate change, lack of law enforcement, poverty, politicalconflict, water stress).

3122
3123
3124
3125
3126
3127
3128
3129

•

The organization’s responsibility regarding the authoritative intergovernmental instrumentswith which it is expected to comply.
Examples include the International Labour Organization (ILO) Tripartite Declaration of
Principles concerning Multinational Enterprises and Social Policy [1]; the Organisation for
Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises[3]; the United Nations (UN) Framework Convention on Climate Change (FCCC) Paris
Agreement [4]; the UN Guiding Principles on Business and Human Rights [5]; and the UN
International Bill of Human Rights [6].

3130
3131

•

The organization’s responsibility regarding the laws and regulations with which it is expected
to comply.

3132

See the Sustainability context principle in GRI 1: Foundation 2021 for more information.

3133

Stakeholders

3134
3135

The organization should identify who its stakeholders are across its activities and business
relationships and engage with them to help identify its impacts.

3136
3137
3138
3139
3140
3141
3142

The organization should draw a full list of individuals and groups whose interests are affected or could
be affected by the organization’s activities. Common categories of stakeholders for organizations arebusiness partners, civil society organizations, consumers, customers, employees and other workers,
governments, local communities, non-governmental organizations, shareholders and other investors,
suppliers, trade unions, and vulnerable groups. The organization can further draw a distinction
between those individuals and groups whose human rights are affected or could be affected, andindividuals and groups with other interests.

Page 95 of 115

3143
3144
3145
3146
3147

When identifying its stakeholders, the organization should ensure it identifies any individuals orgroups it does not have a direct relationship with (e.g., workers in the supply chain or local
communities that live at a distance from the organization’s operations) and those who are unable toarticulate their views (e.g., future generations) but whose interests are affected or could be affectedby the organization’s activities.

3148
3149

Different lists of stakeholders can be drawn per activity, project, product or service, or otherclassification that is relevant for the organization.

3150

See Box 2 in this Standard for information on engaging with stakeholders.

3151

Step 2. Identify actual and potential impacts

3152
3153
3154
3155
3156
3157

In this step, the organization identifies its actual and potential impacts on the economy, environment,
and people, including impacts on their human rights, across the organization’s activities and business
relationships. Actual impacts are those that have already occurred, and potential impacts are thosethat could occur but have not yet occurred. These impacts include negative and positive impacts,
short-term and long-term impacts, intended and unintended impacts, and reversible and irreversible
impacts.

3158
3159
3160
3161
3162
3163

To identify its impacts, the organization can use information from diverse sources. It can use
information from its own or third-party assessments of impacts on the economy, environment, andpeople, including impacts on their human rights. It can also use information from legal reviews, anticorruption compliance management systems, financial audits, occupational health and safety
inspections, and shareholder filings. It can also use information from any other relevant assessmentsof business relationships carried out by the organization or by industry or multi-stakeholder initiatives.

3164
3165
3166
3167
3168
3169

Further information can be gathered through grievance mechanisms that the organization has
established itself, or that have been established by other organizations. The organization can also use
information from broader enterprise risk management systems, provided that these systems identify
the organization’s impacts on the economy, the environment, and people, in addition to identifying
risks for the organization itself. It can also use information from external sources, such as news
organizations and civil society organizations.

3170
3171
3172

In addition, the organization should seek to understand the concerns of its stakeholders (see Box 2 inthis Standard) and consult internal and external experts, such as civil society organizations or
academics.

3173

Box 2. Engaging with relevant stakeholders and experts

3174
3175
3176
3177

The organization should seek to understand the concerns of its stakeholders by consulting them
directly in a way that takes into account language and other potential barriers (e.g., culturaldifferences, gender and power imbalances, divisions within the community). Identifying and removing
potential barriers is necessary to ensure that stakeholder engagement is effective.

3178
3179
3180
3181

Engagement with at-risk or vulnerable groups may necessitate specific approaches and call for
special attention. Such approaches include removing social barriers that limit the participation of
women in public forums and removing physical barriers that prevent remotely located communities
from attending a meeting.

3182
3183
3184

The organization should respect the human rights of all stakeholders and other individuals with whom
it engages (e.g., their rights to privacy, freedom of expression, and peaceful assembly and protest)
and it should protect them against reprisals (i.e., non-retaliation for raising complaints or concerns).

3185
3186
3187
3188
3189

Broad engagement with stakeholders may not be possible in cases that involve many stakeholders orin cases that involve impacts which result in collective harm. For example, broad engagement may
not be possible in the case of corruption, which collectively harms the population of the jurisdiction inwhich it takes place, or in the case of greenhouse gas (GHG) emissions, which contribute tocollective, transboundary harm.

3190
3191
3192

In such cases, the organization may engage with credible stakeholder representatives or proxyorganizations (e.g., non-governmental organizations, trade unions). This is also relevant in cases
where engaging with individuals could undermine certain rights or collective interests. For example,

Page 96 of 115

3193
3194
3195
3196

when considering a decision to restructure or shut down a factory, it may be important for an
organization to engage with trade unions to mitigate the employment impacts of the decision. In sucha case, engaging with individual workers could undermine the right of workers to form or join tradeunions and to bargain collectively.

3197
3198

The degree of impact on stakeholders may inform the degree of engagement. The organization
should prioritize the most severely affected or potentially affected stakeholders for engagement.

3199
3200
3201

Where direct consultation is not possible, the organization should consider reasonable alternatives,
such as consulting credible independent experts, such as national human rights institutions, humanrights and environmental defenders, trade unions, and other members of civil society.

3202

See references [2] and [5] in the Bibliography.

3203
3204

In this step, the organization needs to consider the impacts described in the applicable GRI Sector
Standards and determine whether these impacts apply to it.

3205
3206
3207
3208
3209

Impacts may change over time as the organization’s activities, business relationships, and context
evolve. New activities, new business relationships, and major changes in operations or the operating
context (e.g., new market entry, product launch, policy change, wider changes to the organization)
could lead to changes in the organization’s impacts. For this reason, the organization should assess
its context and identify its impacts on an ongoing basis.

3210
3211
3212

In cases where the organization has limited resources available for identifying its impacts, it should
first identify its negative impacts, before identifying positive impacts, to ensure it complies withapplicable laws, regulations, and authoritative intergovernmental instruments.

3213

Identifying negative impacts

3214
3215
3216
3217
3218

Identifying actual and potential negative impacts with which the organization is involved or could be
involved is the first step of due diligence. The organization should consider actual and potential
impacts that it causes or contributes to through its activities, as well as actual and potential impacts
that are directly linked to its operations, products, or services by its business relationships (see Box 3
in this Standard).

3219
3220
3221
3222
3223
3224
3225
3226

In some cases, the organization might be unable to identify actual and potential negative impacts
across all its activities and business relationships. This could be, for example, because theorganization has diverse or multiple global operations or because its value chain comprises many
entities. In such cases, the organization may carry out an initial assessment or scoping exercise to
identify general areas across its activities and business relationships (e.g., product lines, suppliers
located in specific geographic locations) where negative impacts are most likely to be present andsignificant. Once the organization has conducted the initial assessment or scoping exercise, it canidentify and assess actual and potential negative impacts for these general areas.

3227
3228
3229
3230
3231
3232
3233
3234
3235
3236
3237
3238

As part of the initial assessment or scoping exercise, the organization should consider impacts
commonly associated with its sectors, its products, geographic locations, or with specificorganizations (i.e., impacts associated with a specific entity of the organization, or with an entity it has
a business relationship with, such as a poor history of conduct in relation to respecting human rights).
It should also consider impacts it has been involved with or knows it is likely to be involved with. In
addition to the GRI Sector Standards, the organization can use the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Business Conduct [2]and the OECD sectoral guidance on due diligence [13] for information on impacts commonly
associated with sectors, products, geographic locations, and specific organizations. It can also use
reports from governments, environmental agencies, international organizations, civil society
organizations, workers’ representatives and trade unions, national human rights institutions, media, orother experts.

3239

See references [2], [3], and [5] in the Bibliography.

3240

Box 3. Causing, contributing, or being directly linked to negative impacts

3241
3242
3243

An organization ‘causes’ a negative impact if its activities on their own result in the impact, forexample, if the organization pays a bribe to a foreign public official, or if it withdraws water from awater-stressed aquifer without replenishing the water level.

Page 97 of 115

3244
3245
3246
3247
3248
3249
3250

An organization ‘contributes to’ a negative impact if its activities lead, facilitate, or incentivize
another entity to cause the impact. The organization can also contribute to a negative impact if its
activities in combination with the activities of other entities cause the impact. For example, if theorganization sets a short lead time for a supplier to deliver a product, despite knowing fromexperience that this production time is not feasible, this could result in excessive overtime for the
supplier’s workers. In such a case, the organization may contribute to negative impacts on the healthand safety of these workers.

3251
3252

An organization can cause or contribute to a negative impact through its actions as well as by failure
to take action (e.g., failure to prevent or mitigate a potential negative impact).

3253
3254
3255
3256
3257
3258
3259
3260

Even if an organization does not cause or contribute to a negative impact, its operations, products, orservices may be ‘directly linked to’ a negative impact by its business relationship. For example, if
the organization uses cobalt in its products that is mined using child labor, the negative impact (i.e.,
child labor) is directly linked to the organization’s products through the tiers of business relationships
in its supply chain (i.e., through the smelter and minerals trader, to the mining enterprise that uses
child labor), even though the organization has not caused or contributed to the negative impact itself.
‘Direct linkage’ is not defined by the link between the organization and the other entity, and istherefore not limited to direct contractual relationships, such as ‘direct sourcing’.

3261
3262
3263

The way the organization is involved with negative impacts determines how it should address theimpacts and whether it has a responsibility to provide for or cooperate in their remediation (seesection 2.3 in GRI 1: Foundation 2021).

3264
3265
3266
3267

See references [2] and [5] in the Bibliography. For additional guidance and examples, see theOrganisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for
Responsible Business Conduct [2], pages 70-72, and the United Nations’ (UN) The Corporate
Responsibility to Respect Human Rights: An Interpretive Guide [15], pages 15-18.

3268

Identifying positive impacts

3269
3270
3271
3272
3273
3274

To identify its actual and potential positive impacts, the organization should assess the manner inwhich it contributes or could contribute to sustainable development through its activities, for example,
through its products, services, investments, procurement practices, employment practices, or tax
payments. This also includes assessing how the organization can shape its purpose, business model,
and strategies so that it delivers positive impacts that contribute to the goal of sustainable
development.

3275
3276
3277
3278
3279
3280

An example of a positive impact is an organization adopting measures that lower the cost of
renewable energy for customers, thereby allowing more customers to switch from using nonrenewable energy to renewable energy, and thus contributing to mitigating climate change. Anotherexample is an organization choosing an area with high unemployment to open a new facility so that it
can hire and train unemployed members of the local community, and in this way contribute to job
creation and community development.

3281
3282
3283
3284
3285
3286

The organization should consider any negative impacts that could result from activities that aim for apositive contribution to sustainable development. Negative impacts cannot be offset by positive
impacts. For example, a renewable energy installation may reduce a region’s dependence on fossil
fuels and bring energy to underserved communities. However, if it displaces local indigenous
communities from their lands or territories without their consent, this negative impact should be
addressed and remediated, and it cannot be compensated by the positive impacts.

3287

Step 3. Assess the significance of the impacts

3288
3289
3290
3291
3292

The organization may identify many actual and potential impacts. In this step, the organizationassesses the significance of its identified impacts to prioritize them. Prioritization enables theorganization to take action to address the impacts and also to determine its material topics forreporting. Prioritizing impacts for action is relevant where it is not feasible to address all impacts at
once.

3293
3294

Assessing the significance of the impacts involves quantitative and qualitative analysis. How
significant an impact is will be specific to the organization and will be influenced by the sectors inPage 98 of 115

3295
3296
3297
3298

which it operates and its business relationships, among other factors. In some instances, this mayneed a subjective decision. The organization should consult with relevant stakeholders (see Box 2 inthis Standard) and business relationships to assess the significance of its impacts. The organization
should also consult relevant internal or external experts.

3299

Assessing the significance of negative impacts

3300
3301

The significance of an actual negative impact is determined by the severity of the impact. The
significance of a potential negative impact is determined by the severity and likelihood of the impact.

3302
3303
3304
3305

The combination of the severity and the likelihood of a negative impact can be referred to as ‘risk’.
The assessment of the significance of the impacts can be included within broader enterprise risk
management systems, provided that these systems assess the impacts the organization has on theeconomy, the environment, and people, in addition to assessing risks for the organization itself.

3306

Severity

3307

The severity of an actual or potential negative impact is determined by the following characteristics:

3308

•

Scale: how grave the impact is.

3309
3310

•

Scope: how widespread the impact is, for example, the number of individuals affected or theextent of environmental damage.

3311

•

Irremediable character: how hard it is to counteract or make good the resulting harm.

3312
3313
3314
3315
3316
3317
3318

The scale of a negative impact (i.e., how grave the impact is) can depend on whether the impact
leads to non-compliance with laws and regulations or with authoritative intergovernmental instrumentswith which the organization is expected to comply. For example, if a negative impact leads to aviolation of human rights or fundamental rights at work, or to non-compliance with the reductions ingreenhouse gas (GHG) emissions to be achieved under the United Nations (UN) Framework
Convention on Climate Change (FCCC) Paris Agreement [4], the scale of this impact can beconsidered greater.

3319
3320
3321
3322
3323

The scale of a negative impact can also depend on the context in which the impact takes place. For
example, the scale of the impact of an organization’s water withdrawal can depend on the area fromwhich water is withdrawn. The scale will be greater if water is withdrawn from an area affected bywater stress, compared to an area that has abundant water resources to meet the demands of water
users and ecosystems.

3324
3325
3326

Any of the three characteristics (scale, scope, and irremediable character) can make an impact
severe. But it is often the case that these characteristics are interdependent: the greater the scale or
the scope of an impact, the less remediable it is.

3327
3328
3329
3330
3331
3332

The severity – and therefore the significance – of an impact are not absolute concepts. The severity ofan impact should be assessed in relation to the other impacts of the organization. For example, anorganization should compare the severity of the impacts of its GHG emissions against the severity of
its other impacts. The organization should not assess the significance of its GHG emissions in relation
to global GHG emissions, as that comparison could lead to the misleading conclusion that theorganization’s emissions are not significant.

3333

See references [2], [3], and [5] in the Bibliography.

3334

Likelihood

3335
3336
3337
3338

The likelihood of a potential negative impact refers to the chance of the impact happening. The
likelihood of an impact can be measured or determined qualitatively or quantitatively. It can be
described using general terms (e.g., very likely, likely) or mathematically using probability (e.g., 10 in
100, 10%) or frequency over a given time period (e.g., once every three years).1

3339

Human rights

3340
3341

In the case of potential negative human rights impacts, the severity of the impact takes precedence
over its likelihood. For example, an organization operating a nuclear power facility may prioritize the

1 International Organization for Standardization (ISO), ISO 31000:2018 Risk management – Guidelines, 2018.

Page 99 of 115

3342
3343

potential impact related to loss of life in cases of natural disasters affecting the power facility, eventhough natural disasters are less likely to occur than other incidents.

3344
3345
3346
3347

The severity of a negative human rights impact is not limited to physical harm. Highly severe impacts
can occur in relation to any human right. For example, interfering with, damaging, or destroying asacred space without consultation or agreement with the people for whom the space has spiritual
importance can have a highly severe impact on their cultural rights.

3348
3349

When prioritizing other types of impacts, such as potential negative environmental impacts, theorganization may also choose to prioritize them based on severity alone.

3350

Assessing the significance of positive impacts

3351
3352
3353

The significance of an actual positive impact is determined by the scale and scope of the impact. The
significance of a potential positive impact is determined by the scale and scope as well as thelikelihood of the impact.

3354

Scale and scope

3355
3356
3357

In the case of positive impacts, the scale of an impact refers to how beneficial the impact is or could
be, and the scope refers to how widespread the impact is or could be (e.g., the number of individuals
or the extent of environmental resources that are or could be positively affected).

3358

Likelihood

3359
3360
3361
3362

The likelihood of a potential positive impact refers to the chance of the impact happening. The
likelihood of an impact can be measured or determined qualitatively or quantitatively. It can be
described using general terms (e.g., very likely, likely) or mathematically using probability (e.g., 10 in
100, 10%) or frequency over a given time period (e.g., once every three years).2

3363

Step 4. Prioritize the most significant impacts for reporting

3364
3365

In this step, to determine its material topics for reporting, the organization prioritizes its impacts basedon their significance.

3366

Setting a threshold to determine which topics are material

3367
3368
3369
3370
3371

The significance of an impact is assessed in relation to the other impacts the organization has
identified. The organization should arrange its impacts from most to least significant and define a cutoff point or threshold to determine which of the impacts it will focus its reporting on. The organization
should document this threshold. To facilitate prioritization, the organization should group the impacts
into topics (see Box 4 in this Standard).

3372
3373
3374
3375
3376
3377

For example, when setting a threshold, the organization first groups its impacts into a number of
topics and ranks them, based on their significance, from highest to lowest priority. The organization
then needs to determine how many of the topics it will report on, starting with those that have thehighest priority. Where to set the threshold is up to the organization. For transparency, theorganization can provide a visual representation of the prioritization that shows the initial list of topics
it has identified and the threshold it has set for reporting.

3378
3379
3380
3381
3382
3383

The significance of an impact is the sole criterion to determine whether a topic is material forreporting. The organization cannot use difficulty in reporting on a topic, or the fact that it does not yet
manage the topic, as criteria to determine whether or not to report on the topic. In cases where theorganization does not manage a material topic, it can report the reasons for not doing so, or any plans
to manage the topic, to comply with the requirements in Disclosure 3-3 Management of material
topics in this Standard.

3384
3385
3386

While some topics can cover both negative and positive impacts, it may not always be possible tocompare the two. Additionally, negative impacts cannot be offset by positive impacts. The
organization should therefore prioritize negative impacts separately from positive impacts.

2 International Organization for Standardization (ISO), ISO 31000:2018 Risk management – Guidelines, 2018.

Page 100 of 115

3387
3388
3389
3390

Even if the organization has not prioritized an actual or potential negative impact for reporting, it may
still have a responsibility to address the impact in line with applicable laws, regulations, orauthoritative intergovernmental instruments. See section 2.3 in GRI 1: Foundation 2021 for more
information.

3391

Box 4. Grouping impacts into topics

3392
3393

Grouping impacts into topics, like ‘water and effluents’, helps the organization report in a cohesive
way about multiple impacts that relate to the same topic.

3394
3395
3396
3397
3398
3399

The organization can group impacts into topics according to general categories that relate to abusiness activity, stakeholder category, type of business relationship, or an economic or
environmental resource. For example, an organization’s activities result in water pollution, whichcauses negative impacts on both ecosystems and on local communities’ access to safe drinking
water. The organization can group these impacts into the topic of ‘water and effluents’ as both
impacts relate to its use of water.

3400
3401
3402
3403

The organization can refer to the topics in the GRI Topic Standards and the GRI Sector Standards.
These topics provide a useful reference for understanding the range of impacts that can be covered ineach topic. For impacts or topics that are not covered by the GRI Standards, the organization canrefer to other sources, such as authoritative intergovernmental instruments or industry standards.

3404

Testing the material topics

3405
3406
3407

The organization should test its selection of material topics against the topics in the applicable GRISector Standards. This helps the organization ensure that it has not overlooked any topics that arelikely to be material for its sectors.

3408
3409
3410
3411
3412

The organization should also test its selection of material topics with potential information users andexperts who understand the organization or its sectors and have insight into one or more of thematerial topics. This can help the organization validate the threshold it has set to determine which
topics are material to report. Examples of experts the organization can consult are academics,
consultants, investors, lawyers, national institutions, and non-governmental organizations.

3413
3414
3415

The organization should seek external assurance to assess the quality and credibility of its process ofdetermining material topics. See section 5.2 in GRI 1 for more information on seeking external
assurance.

3416

This testing process results in a list of the organization’s material topics.

3417

Approval of the material topics

3418
3419
3420

The organization’s highest governance body should review and approve the list of material topics. If
such a body does not exist, the list should be approved by a senior executive or group of senior
executives in the organization.

3421

Determining what to report for each material topic

3422
3423
3424

Once the organization has determined its material topics, it needs to determine what to report foreach material topic. See Requirement 4 and Requirement 5 in GRI 1 for information about how toreport on material topics.

3425

Box 5. Using GRI Sector Standards to determine material topics

3426
3427
3428

The GRI Sector Standards provide information for organizations about their likely material topics. The
topics have been identified on the basis of the sectors’ most significant impacts, using multistakeholder expertise, authoritative intergovernmental instruments, and other relevant evidence.

3429
3430
3431
3432

The organization is required to use the applicable Sector Standards when determining its material
topics (see Requirement 3-b in GRI 1: Foundation 2021). Using the Sector Standards is not a
substitute for the process of determining material topics, but an aid. The organization still needs toconsider its own specific circumstances when determining its material topics.

3433
3434

The organization is required to review each topic described in the applicable Sector Standards anddetermine whether it is a material topic for the organization.

Page 101 of 115

3435
3436
3437
3438

There can be cases where a topic included in the applicable Sector Standards is not material for theorganization. This may be because the organization assesses the specific impacts the topic covers to
be absent. It may also be because, compared to other impacts of the organization, the ones that the
topic covers are not among the most significant.

3439
3440
3441
3442
3443
3444
3445
3446
3447
3448

For example, an organization in the oil and gas sector is required to use GRI 11: Oil and Gas Sector
2021 when determining its material topics. One of the topics included in this Sector Standard is land
and resource rights. Oil and gas projects often require land for operations, access routes, anddistribution. This can lead to impacts such as involuntary resettlement of local communities, which
can involve their physical displacement, as well as economic displacement through lost access toresources. However, if the organization’s oil and gas projects do not result in these impacts and will
not result in these impacts in the future, the organization may determine that the topic of land andresource rights is not a material topic for the organization. In such a case, the reporting organization isrequired to explain why it has determined that this topic, which is likely to be material for organizationsin the oil and gas sector, is not a material topic for the organization.

3449
3450
3451
3452
3453

If any of the topics that are included in the applicable Sector Standards have been determined by theorganization as not material, the organization is required to list them in the GRI content index and
explain why they are not material (see Requirement 3-b-ii in GRI 1). This explanation helps
information users understand why the organization has determined that topics identified as likely to bematerial for the organization’s sectors are not material in its specific circumstances.

3454
3455
3456
3457

A brief explanation in the GRI content index of why the topic is not material is sufficient to comply with
Requirement 3-b-ii in GRI 1. In the previous example, the organization could explain that land andresource rights is not a material topic because its existing oil and gas projects are located inuninhabited areas and there are no plans to start projects in new areas.

3458

2. Disclosures on material topics

3459
3460
3461
3462
3463
3464

The disclosures in this section provide information about the organization’s material topics, how theorganization has determined these topics, and how it manages each material topic. Material topics
are topics that represent the organization’s most significant impacts on the economy, environment,
and people, including impacts on their human rights. Section 1 of this Standard provides guidance on
how to determine material topics and helps in understanding and reporting the disclosures in thissection.

3465

Disclosure 3-1 Process to determine material topics

3466

Requirements

3467

The organization shall:

3468

a. describe the process it has followed to determine its material topics, including:

3469
3470
3471

i.

how it has identified actual and potential, negative and positive impacts on theeconomy, environment, and people, including impacts on their human rights,
across its activities and business relationships;

3472

ii.

how it has prioritized the impacts for reporting based on their significance;

3473
3474

b. specify the stakeholders and experts whose views have informed the process ofdetermining its material topics.

3475

Guidance

3476
3477

This disclosure requires information on how the organization has determined its material topics. The
list of material topics is reported under Disclosure 3-2 in this Standard.

Page 102 of 115

3478
3479
3480
3481
3482

The organization is required to use the applicable GRI Sector Standards when determining its
material topics. If any of the topics that are included in the applicable Sector Standards have been
determined by the organization as not material, the organization is required to list them in the GRI
content index and explain why they are not material. See Requirement 5 and Requirement 7 in GRI 1:
Foundation 2021 and Box 5 in this Standard for more information.

3483
3484
3485
3486
3487
3488

In the absence of applicable Sector Standards, the organization should explain how it has considered
impacts commonly associated with its sectors, and whether any of these impacts have been
determined as not material, together with an explanation for why this is the case. The organization
should also explain how it has considered impacts commonly associated with its products andgeographic locations. See section 1 in this Standard and the Sector Standards for guidance on
impacts commonly associated with sectors, products, and geographic locations.

3489

Guidance to 3-1-a-i

3490
3491
3492
3493

The organization should describe the methods it has used to identify its impacts, for example,
economic, environmental, social, and human rights impact assessments, grievance mechanisms, orusing information from external sources, such as civil society organizations. The organization should
describe the sources and the evidence it has used to identify the impacts.

3494
3495
3496
3497

The organization should also describe the scope it has defined when identifying the impacts, forexample, whether it has identified short-term as well as long-term impacts. The organization should
also describe any limitations or exclusions, for example, whether it has excluded business
relationships from certain parts of its value chain when identifying the impacts.

3498
3499
3500

Disclosure 2-12 in GRI 2: General Disclosures 2021 requires information on the role of the highest
governance body in overseeing the organization’s due diligence and other processes to identify its
impacts on the economy, environment, and people.

3501

Guidance to 3-1-a-ii

3502
3503

The organization should describe how it has assessed the significance of the impacts, including any
assumptions and subjective judgements it has made.

3504
3505
3506
3507

The significance of an actual negative impact is determined by the severity of the impact (scale,scope, and irremediable character), while the significance of a potential negative impact is determinedby the severity and likelihood of the impact. In the case of potential negative human rights impacts,
the severity of the impact takes precedence over its likelihood.

3508
3509
3510

The significance of an actual positive impact is determined by the scale and scope of the impact,
while the significance of a potential positive impact is determined by its scale and scope as well as its
likelihood.

3511

See section 1 in this Standard for more guidance on assessing the significance of impacts.

3512
3513

The organization should explain if it has used a different approach to prioritize its impacts, forexample, if it has prioritized potential negative environmental impacts based on severity only.

3514
3515
3516
3517
3518
3519
3520

The organization should also describe how it has defined the threshold to determine which topics arematerial for reporting, and whether it has tested its selection of material topics with potential
information users and experts. The organization is required to report whether the highest governancebody is responsible for reviewing and approving the reported information, including the organization’smaterial topics, under Disclosure 2-14 in GRI 2. The organization should explain any changes to its
initial selection of material topics following internal approval and testing with potential information
users and experts.

3521
3522

For transparency, the organization can provide a visual representation of the prioritization that shows
the initial list of topics it has identified and the threshold it has set for reporting.

3523

Guidance to 3-1-b

3524
3525

Requirement 3-1-b enables the organization to explain how engagement with stakeholders andexperts informs the ongoing identification and assessment of its impacts.

3526
3527
3528

The organization can report whether and how it has prioritized stakeholders for engagement and themethods used to engage with them. It can also report any conflicting interests that have arisen among
different stakeholders and how the organization has resolved these conflicting interests.

Page 103 of 115

3529

Disclosure 3-2 List of material topics

3530

Requirements

3531

The organization shall:

3532

a. list its material topics;3533

b. report changes to the list of material topics compared to the previous reporting period.

3534

Guidance

3535
3536

This disclosure requires information on the organization’s material topics. The process of determining
material topics is reported under Disclosure 3-1 in this Standard.

3537
3538
3539
3540
3541

The organization is required to include the material topics listed under this disclosure in the GRI
content index. If any of the topics that are included in the applicable Sector Standards have been
determined by the organization as not material, the organization is required to list them in the content
index and explain why they are not material. See Requirement 5 and Requirement 7 in GRI 1:
Foundation 2021 for more information.

3542

Guidance to 3-2-a

3543
3544
3545

The organization can group material topics by relevant categories if this helps communicate its
impacts. For example, the organization can indicate which of its material topics represent its negative
human rights impacts.

3546

Guidance to 3-2-b

3547
3548
3549

Requirement 3-2-b enables the organization to explain why a topic that it determined as material in
the previous reporting period is no longer considered to be material, or why a new topic has been
determined as material for the current reporting period.

Page 104 of 115

3550

Disclosure 3-3 Management of material topics

3551

Requirements

3552

For each material topic reported under Disclosure 3-2, the organization shall:

3553
3554

a. describe the actual and potential, negative and positive impacts on the economy,
environment, and people, including impacts on their human rights;

3555
3556
3557

b. report whether the organization is involved with the negative impacts through its activities
or as a result of its business relationships, and describe the activities or business
relationships;

3558

c. describe its policies or commitments regarding the material topic;

3559

d. describe actions taken to manage the topic and related impacts, including:

3560

i.

3561
3562

ii. actions to address actual negative impacts, including actions to provide for orcooperate in their remediation;

3563

iii. actions to manage actual and potential positive impacts;

3564

actions to prevent or mitigate potential negative impacts;

e. report the following information about tracking the effectiveness of the actions taken:

3565

i.

3566

ii. goals, targets, and indicators used to evaluate progress;

3567

iii. the effectiveness of the actions, including progress toward the goals and targets;

3568
3569

iv. lessons learned and how these have been incorporated into the organization’s
operational policies and procedures;processes used to track the effectiveness of the actions;

3570
3571

f.

describe how engagement with stakeholders has informed the actions taken (3-3-d) and
how it has informed whether the actions have been effective (3-3-e).

3572

Guidance

3573
3574
3575

This disclosure requires the organization to explain how it manages each of its material topics. Thismeans that the organization is required to report this disclosure for each of its material topics. The
requirements in this disclosure apply to every material topic.

3576
3577
3578
3579
3580
3581

In addition to this disclosure, there may also be disclosures and guidance in the Topic Standards andSector Standards that address reporting information about how the organization manages a topic. For
example, some Topic Standards contain disclosures about specific actions or methods to manage a
topic. The organization does not need to repeat this information under Disclosure 3-3 if it is alreadyreported under another disclosure. The organization can report the information once and provide areference to this information to fulfill the corresponding requirements in Disclosure 3-3.

3582
3583
3584
3585

If the organization’s approach to managing a material topic, such as its policies or actions taken,
applies to other material topics, the organization does not need to repeat this information for each
topic. The organization can report this information once, with a clear explanation of all the topics itcovers.

3586
3587
3588
3589
3590

If the organization cannot report the required information about an item specified in this disclosure
because the item (e.g., policy, action) does not exist, it can comply with the requirement by reporting
this to be the case. The organization can explain the reasons for not having this item, or describe anyplans 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.

Page 105 of 115

3591
3592

If the organization does not manage a material topic, it can comply with the requirements under thisdisclosure by explaining the reasons for not managing the topic or describing any plans to manage it.

3593

Guidance to 3-3-a

3594
3595
3596
3597

Requirement 3-3-a enables the organization to indicate if a topic is material because of negative
impacts, positive impacts, or both. It does not require a list of all the impacts identified or a detailed
description of the impacts. Instead, the organization can provide a high-level overview of the impacts
it has identified.

3598

Describing negative impacts

3599

The organization can describe:

3600

•

whether the negative impacts are actual or potential;

3601
3602

•

the time frame of the negative impacts (i.e., whether the negative effects are short-term or
long-term and when they are likely to arise);

3603
3604
3605

•

whether the negative impacts are systemic (e.g., child labor or forced labor in countries where
the organization operates or sources materials from) or are related to individual incidents(e.g., an oil spill);

3606
3607
3608

•

the economic resources, environmental resources, and stakeholders (without identifying
specific individuals) that are negatively affected or could be negatively affected, including theirgeographic location.

3609
3610
3611
3612
3613
3614
3615
3616
3617

Reporting information about negative impacts can help the organization demonstrate that itrecognizes these impacts and that it has taken action or intends to take action to address them. The
organization may have concerns about reporting information about negative impacts even if these
impacts are publicly known. In cases where negative impacts are publicly known, failure toacknowledge these impacts and to explain how they are being addressed could have consequences
for the organization financially, operationally, or reputationally. If the organization is unable to disclose
specific information (e.g., because of stakeholders’ right to privacy), it can provide the information inaggregated or anonymized form, or it can make a reference to the impacts commonly associated with
its sectors, its products, or geographic locations. [11]3618

Describing positive impacts

3619

The organization can describe:

3620

•

whether the positive impacts are actual or potential;

3621
3622

•

the time frame of the positive impacts (i.e., whether the positive effects are short-term or longterm and when they are likely to arise);

3623
3624

•

the activities that result in the positive impacts (e.g., products, services, investments,
procurement practices);

3625
3626
3627

•

the economic resources, environmental resources, and stakeholders (without identifying
specific individuals) that are positively affected or could be positively affected, including theirgeographic location.

3628

Guidance to 3-3-b

3629
3630
3631
3632
3633

The way the organization is involved with negative impacts determines how it should address theimpacts, and whether it has a responsibility to provide for or cooperate in their remediation (seesection 2.3 in GRI 1: Foundation 2021). Requirement 3-3-b provides contextual information that aids
an understanding of the actions taken by the organization to manage its negative impacts. The
actions taken are reported under 3-3-d-i and 3-3-d-ii.

3634
3635
3636

Under requirement 3-3-b, the organization is required to report whether it is involved with the negative
impacts through its activities or as a result of its business relationships. Where possible, theorganization should also report:

3637
3638

•

whether it is or could be causing or contributing to the negative impacts through its activities;
orPage 106 of 115

3639
3640

•

whether the impacts are or could be directly linked to its operations, products, or services by
its business relationships even if it has not contributed to them.

3641
3642

See Box 3 in this Standard for more information on causing, contributing, or being directly linked tonegative impacts.

3643
3644
3645
3646

Under requirement 3-3-b, the organization is also required to describe the activities or business
relationships. This enables the organization to indicate if the impacts related to a material topic arewidespread in the organization’s activities or business relationships, or if the impacts concern specificactivities or business relationships.

3647
3648
3649
3650

If the impacts concern specific activities, the organization should describe the types of activities (e.g.,
manufacturing, retail) and their geographic location. If the impacts concern specific business
relationships, the organization should describe the types of business relationships (e.g., suppliers of
raw materials, franchisees), their position in the value chain, and their geographic location.

3651
3652
3653
3654
3655
3656

For example, if the organization has identified that its activities at specific sites could cause waterpollution, it should describe the types of activities carried out at these sites and the geographic
location of these sites. Or if the organization has identified that it is directly linked to child labor by thebusiness relationships in its supply chain, it should specify the types of suppliers using child labor(e.g., sub-contractors doing embroidery work for the organization’s products) and the geographic
location of these suppliers.

3657
3658
3659
3660
3661

The organization can provide additional contextual information for understanding the extent of its
impacts. Adding to the previous examples, the organization can report how many of its sites could
cause water pollution (e.g., 60% of sites, five out of 12 sites) or the proportion of production thesesites represent, or it can report the estimated number of sub-contractors using child labor that doembroidery work for the organization.

3662

Guidance to 3-3-c

3663
3664
3665
3666
3667
3668

Requirement 3-3-c entails describing the policies or commitments the organization has developed
specifically for the topic, in addition to the policy commitments reported under Disclosure 2-23 in GRI
2: General Disclosures 2021. If the organization has described its policies for a material topic under
Disclosure 2-23, it can provide a reference to this information under 3-3-c and does not need torepeat the information. See Disclosure 2-23 in GRI 2 for guidance on how to report information about
policies.

3669
3670

When reporting its commitments regarding the material topic, the organization should provide astatement of intent to manage the topic, or explain:

3671

•

the organization’s stance on the topic;

3672
3673

•

whether the commitment to manage the topic is based on regulatory compliance or extends
beyond it;

3674

•

compliance with authoritative intergovernmental instruments related to the topic.

3675

Guidance to 3-3-d

3676
3677
3678

Requirement 3-3-d enables the organization to explain how it responds to its impacts. It does not
require a detailed description of actions taken in relation to each impact. Instead, the organization can
provide a high-level overview of how it manages its impacts.

3679
3680

The organization should report how it integrates the findings from its identification and assessment of
impacts across relevant internal functions and processes, including:

3681
3682

•

the level and function within the organization that has been assigned responsibility for
managing the impacts;

3683
3684

•

the internal decision-making, budget allocation, and oversight processes (e.g., internal audit)
to enable effective actions to manage the impacts.

3685
3686
3687

Disclosure 2-12 and Disclosure 2-13 in GRI 2 require information on the role of the highest
governance body in overseeing the management of the organization’s impacts and on how itdelegates responsibility for this.

Page 107 of 115

3688
3689

The organization should also report how it manages actual impacts that were identified in previous
reporting periods and which it continues to manage during the current reporting period.

3690

Guidance to 3-3-d-i

3691

The organization should report:

3692
3693

•

examples of actions taken to prevent or mitigate potential negative impacts (e.g.,
adaptation/modification measures, facility upgrading, training, red-flag systems);

3694

•

approaches taken to prevent or mitigate systemic negative impacts;

3695

•

how the organization applies the precautionary principle, including:

3696
3697

-

how the organization proactively informs the public about potential negative impacts of its
activities, products, and services, and how it deals with related questions and complaints;

3698
3699

-

the organization’s support or contribution to scientific research related to evaluating
potential negative impacts of its activities, products, and services;

3700
3701

-

the organization’s participation in collaborative efforts to share knowledge and to prevent
negative impacts of its activities, products, and services;

3702
3703
3704
3705
3706

•

how the organization uses or increases its leverage to motivate its business relationships toprevent or mitigate potential negative impacts. For example, whether the organization uses orincreases its leverage by enforcing contractual requirements, implements incentives such as
future orders, provides training and support, or actively collaborates with other actors tomotivate its business relationships to prevent or mitigate potential negative impacts;

3707
3708
3709

•

whether the organization has terminated a business relationship because it lacks the leverage
to prevent or mitigate potential negative impacts and, if so, whether it has assessed if
terminating the relationship could itself result in negative impacts.

3710

See Guidance to 2-23-a-iii in GRI 2 for more information on ‘precautionary principle’.

3711

Guidance to 3-3-d-ii

3712

The organization should report:

3713
3714

•

examples of actions taken to remediate actual negative impacts, including examples of
specific remedies or types of remedy provided;

3715
3716

•

how grievance mechanisms or other remediation processes (reported under Disclosure 2-25
in GRI 2) have made it possible for actual negative impacts to be remediated.

3717

See Disclosure 2-25 in GRI 2 for more information on processes to remediate negative impacts.

3718

Guidance to 3-3-e

3719
3720
3721
3722

Requirement 3-3-e enables the organization to report information about the effectiveness of its actions
to manage its impacts. Tracking the effectiveness of its actions is necessary for an organization sothat it can learn if its policies and processes are being implemented optimally. It is also necessary forknowing if it has responded effectively to its impacts and to drive continuous improvement.

3723
3724
3725

The organization should also report information about the effectiveness of its actions to manage
actual impacts from previous reporting periods. This applies in cases where the organization has
assessed the effectiveness of these actions or derived lessons during the current reporting period.

3726

Guidance to 3-3-e-i

3727
3728
3729

Processes used to track the effectiveness of actions can include internal or external auditing orverification, impact assessments, measurement systems, stakeholder feedback, grievancemechanisms, external performance ratings, and benchmarking.

3730

Guidance to 3-3-e-ii

3731

When reporting on goals and targets, the organization should report:

3732

•

how the goals and targets are set;

Page 108 of 115

3733
3734
3735
3736

•

whether and how the goals and targets take into account the sustainability context in which
the impacts take place (e.g., sustainable development goals and conditions, the limits anddemands placed on environmental resources). See the Sustainability context principle in GRI
1 for more information;

3737
3738

•

whether the goals and targets are informed by expectations in authoritative intergovernmental
instruments and, where relevant, by scientific consensus;

3739
3740

•

whether goals and targets are mandatory (based on legislation) or voluntary. If they aremandatory, the organization can list the relevant legislation;

3741

•

the organization’s activities or business relationships to which the goals and targets apply;

3742

•

the baseline for the goals and targets;

3743

•

the timeline for achieving the goals and targets.

3744
3745
3746

Targets can be qualitative (e.g., implementing a management system by a certain date) or
quantitative (e.g., reducing greenhouse gas [GHG] emissions by a certain percentage by a certain
date).

3747
3748
3749
3750
3751

The indicators used to evaluate progress can also be qualitative or quantitative. Quantitative
indicators can bring precision and enable comparisons. Qualitative information is often needed to put
quantitative information into context, enable its interpretation, and determine which comparisons andconclusions are likely to be most valid. The Topic Standards and Sector Standards include qualitativeand quantitative indicators.

3752

Guidance to 3-3-e-iii

3753
3754
3755
3756
3757

Requirement 3-3-e-iii enables the organization to show the extent to which the actions taken havebeen effective. Information on the effectiveness of the actions can be obtained, for example, from theoutcomes of internal or external auditing or verification, data collected through measurement systems,
and stakeholder feedback. The organization should show that there is a credible link between thespecific action taken by the organization and the effective management of impacts.

3758
3759
3760
3761
3762

For example, to show the effectiveness of the actions it has taken to support its suppliers withimproving their working conditions, the organization can report survey feedback from the suppliers’
workers showing that working conditions have improved. Additional information the organization can
provide include data showing a decrease in the number of incidents identified through independent
audits.

3763
3764
3765

Similarly, to demonstrate the effectiveness of its actions to improve the quality of its water discharge,
the organization can report data showing a decrease in the concentration of total dissolved solids(mg/L) in the water discharge.

3766
3767
3768

When reporting progress toward its goals and targets, the organization should report whether
progress is satisfactory or not. If a goal or target has not been achieved, the organization should
explain why.

3769

Guidance to 3-3-e-iv

3770
3771

Managing impacts is typically an ongoing process requiring continuous improvement based onlearning from practice.

3772
3773
3774

The organization is not required to provide a detailed description of lessons learned in relation to eachmaterial topic. Instead, the organization can provide examples to show how it incorporates lessons
learned to manage impacts more successfully in the future.

3775
3776
3777
3778

For example, the organization can briefly describe lessons learned that have led to changes in its
policies or practices (e.g., training for workers, giving additional attention to the performance of
suppliers), or that have led to plans for changes that will manage impacts more successfully in the
future.

3779
3780

Lessons learned may be derived from the organization’s own processes (e.g., root cause analysis),from its business relationships, or from stakeholder or expert feedback.

Page 109 of 115

3781

Guidance to 3-3-f

3782
3783
3784

The organization can explain, for example, whether and how affected stakeholders have been
involved in determining an appropriate remedy for a negative impact, or how stakeholder feedback isused to assess the effectiveness of the actions taken.

Page 110 of 115

3785

Glossary

3786
3787

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

3788
3789
3790

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.

3791

business partner

3792
3793

entity with which the organization has some form of direct and formal engagement for the purpose of
meeting its business objectives

3794

Source: Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015; modified

3795
3796

Examples: affiliates, business-to-business customers, clients, first-tier suppliers, franchisees, joint
venture partners, investee companies in which the organization has a shareholding position

3797

Note: Business partners do not include subsidiaries and affiliates that the organization controls.

3798

business relationships

3799
3800
3801

relationships that the organization has with business partners, with entities in its value chain including
those beyond the first tier, and with any other entities directly linked to its operations, products, orservices

3802
3803

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

3804
3805
3806

Note: Examples of other entities directly linked to the organization’s operations, products, or services
are a non-governmental organization with which the organization delivers support to a local
community, or state security forces that protect the organization’s facilities.

3807

due diligence

3808
3809

process to identify, prevent, mitigate, and account for how the organization addresses its actual andpotential negative impacts

3810
3811
3812

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; and Organisation for Economic Cooperation and Development (OECD), OECD Guidelines for Multinational Enterprises, 2011; modified

3813

Note: See section 2.3 in GRI 1: Foundation 2021 for more information on ‘due diligence’.

3814

employee

3815
3816

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

3817

full-time employee

3818
3819

employee whose working hours per week, month, or year are defined according to national law orpractice regarding working time

3820

grievance mechanism

3821

routinized process through which grievances can be raised and remedy can be sought

3822
3823

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

3824
3825

Note: See Guidance to Disclosure 2-25 in GRI 2: General Disclosures 2021 for more information on‘grievance mechanism’.

Page 111 of 115

3826

highest governance body3827

governance body with the highest authority in the organization

3828
3829
3830
3831

Note: In some jurisdictions, governance systems consist of two tiers, where supervision andmanagement are separated or where local law provides for a supervisory board drawn from nonexecutives to oversee an executive management board. In such cases, both tiers are included under
the definition of highest governance body.

3832

human rights

3833
3834
3835
3836

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

3837
3838

Source: United Nations (UN), Guiding Principles on Business and Human Rights: Implementing theUnited Nations “Protect, Respect and Remedy” Framework, 2011; modified

3839
3840

Note: See Guidance to 2-23-b-i in GRI 2: General Disclosures 2021 for more information on ‘humanrights’.

3841

impact

3842
3843
3844

effect 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

3845
3846

Note 1: Impacts can be actual or potential, negative or positive, short-term or long-term, intended orunintended, and reversible or irreversible.

3847

Note 2: See section 2.1 in GRI 1: Foundation 2021 for more information on ‘impact’.

3848

local community

3849
3850

individuals or groups of individuals living or working in areas that are affected or that could be affectedby the organization’s activities

3851
3852

Note: The local community can range from those living adjacent to the organization’s operations tothose living at a distance.

3853

material topics

3854
3855

topics that represent the organization’s most significant impacts on the economy, environment, andpeople, including impacts on their human rights

3856
3857

Note: See section 2.2 in GRI 1: Foundation 2021 and section 1 in GRI 3: Material Topics 2021 formore information on ‘material topics’.

3858

mitigation

3859

action(s) taken to reduce the extent of a negative impact

3860
3861
3862
3863

Note: The mitigation of an actual negative impact refers to actions taken to reduce the severity of thenegative impact that has occurred, with any residual impact needing remediation. The mitigation of apotential negative impact refers to actions taken to reduce the likelihood of the negative impact
occurring.

3864
3865

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; modified

Page 112 of 115

3866

non-guaranteed hours employee

3867
3868

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

3869

Examples: casual employees, employees with zero-hour contracts, on-call employees

3870

Source: ShareAction, Workforce Disclosure Initiative Survey Guidance Document, 2020; modified

3871

part-time employee

3872
3873

employee whose working hours per week, month, or year are less than the number of working hours
for full-time employees

3874

permanent employee

3875
3876

employee with a contract for an indeterminate period (i.e., indefinite contract) for full-time or part-time
work

3877

remedy / remediation

3878

means to counteract or make good a negative impact / provision of remedy

3879
3880
3881

Examples: apologies, restitution, restoration, rehabilitation, financial or non-financial compensation,and punitive sanctions (whether criminal or administrative, such as fines), prevention of harm throughinjunctions or guarantees of non-repetition

3882
3883

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; modified

3884

reporting period

3885

specific time period covered by the reported information

3886

Examples: fiscal year, calendar year

3887

senior executive

3888
3889

high-ranking member of the management of the organization, such as the Chief Executive Officer(CEO) or an individual reporting directly to the CEO or the highest governance body3890

severity (of an impact)

3891
3892
3893

The severity of an actual or potential negative impact is determined by its scale (i.e., how grave theimpact is), scope (i.e., how widespread the impact is), and irremediable character (how hard it is tocounteract or make good the resulting harm).

3894
3895
3896

Source: United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012; and the Organisation for Economic Co-operation and Development (OECD), OECD Due
Diligence Guidance for Responsible Business Conduct, 2018; modified

3897

Note: See section 1 in GRI 3: Material Topics 2021 for more information on ‘severity’.

3898

stakeholder

3899
3900

individual or group that has an interest that is affected or could be affected by the organization’s
activities

3901
3902

Source: Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018; modified

3903
3904
3905

Examples: business partners, civil society organizations, consumers, customers, employees andother workers, governments, local communities, non-governmental organizations, shareholders andother investors, suppliers, trade unions, vulnerable groups

3906

Note: See section 2.4 in GRI 1: Foundation 2021 for more information on ‘stakeholder’.

Page 113 of 115

3907

supplier

3908
3909

entity upstream from the organization (i.e., in the organization’s supply chain), which provides a
product or service that is used in the development of the organization’s own products or services

3910
3911

Examples: brokers, consultants, contractors, distributors, franchisees, home workers, independent
contractors, licensees, manufacturers, primary producers, sub-contractors, wholesalers

3912
3913

Note: A supplier can have a direct business relationship with the organization (often referred to as
first-tier supplier) or an indirect business relationship.

3914

supply chain

3915
3916

range of activities carried out by entities upstream from the organization, which provide products orservices that are used in the development of the organization’s own products or services

3917

sustainable development / sustainability

3918
3919

development that meets the needs of the present without compromising the ability of future
generations to meet their own needs

3920

Source: World Commission on Environment and Development, Our Common Future, 1987

3921
3922

Note: In the GRI Standards, the terms ‘sustainability’ and ‘sustainable development’ are usedinterchangeably.

3923

temporary employee

3924
3925
3926

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)

3927

value chain

3928
3929

range of activities carried out by the organization, and by entities upstream and downstream from theorganization, to bring the organization’s products or services from their conception to their end use

3930
3931
3932

Note 1: Entities upstream from the organization (e.g., suppliers) provide products or services that areused in the development of the organization’s own products or services. Entities downstream from theorganization (e.g., distributors, customers) receive products or services from the organization.

3933

Note 2: The value chain includes the supply chain.

3934

vulnerable group

3935
3936
3937

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

3938
3939
3940
3941
3942
3943

Examples: children and youth; elderly persons; ex-combatants; HIV/AIDS-affected households;
human rights defenders; indigenous peoples; internally displaced persons; migrant workers and theirfamilies; national or ethnic, religious and linguistic minorities; persons who might be discriminatedagainst based on their sexual orientation, gender identity, gender expression, or sex characteristics(e.g., lesbian, gay, bisexual, transgender, intersex); persons with disabilities; refugees or returning
refugees; women

3944

Note: Vulnerabilities and impacts can differ by gender.

3945

worker3946

person that performs work for the organization

3947
3948

Examples: employees, apprentices, interns, self-employed persons, and persons working fororganizations other than the reporting organization, such as for suppliers

3949
3950

Note: In the GRI Standards, in some cases it is specified whether a particular subset of workers is
required to be used.

Page 114 of 115

3951

Bibliography

3952
3953

This section lists authoritative intergovernmental instruments and additional references used indeveloping this Standard, as well as resources that can be consulted the organization.

3954

Authoritative instruments:

3955
3956

1. International Labour Organization (ILO), Tripartite Declaration of Principles concerning
Multinational Enterprises and Social Policy, 2017.

3957
3958

2. Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018.

3959
3960

3. Organisation for Economic Co-operation and Development (OECD), OECD Guidelines forMultinational Enterprises, 2011.

3961

4. United Nations (UN), Framework Convention on Climate Change (FCCC) Paris Agreement, 2015.

3962
3963

5. United Nations (UN), Guiding Principles on Business and Human Rights: Implementing the United
Nations “Protect, Respect and Remedy” Framework, 2011.

3964

6. United Nations (UN), International Bill of Human Rights:

3965

6.1

United Nations (UN), Universal Declaration of Human Rights, 1948.

3966

6.2

United Nations (UN), International Covenant on Civil and Political Rights, 1966.

3967
3968

6.3

United Nations (UN), International Covenant on Economic, Social, and Cultural Rights,
1966.

3969
3970

6.4

United Nations (UN), Optional Protocol to the International Covenant on Civil andPolitical Rights, 1966.

3971
3972

6.5

United Nations (UN), Second Optional Protocol to the International Covenant on Civil
and Political Rights, aiming at the abolition of the death penalty, 1989.

3973
3974

7. United Nations (UN), Protect, Respect and Remedy: a Framework for Business and Human
Rights, 2008.

3975
3976
3977

8. United Nations (UN), Report of the Special Representative of the Secretary-General on the Issueof Human Rights and Transnational Corporations and Other Business Enterprises, John Ruggie,
2011.

3978

9. United Nations (UN), Rio Declaration on Environment and Development, 1992.

3979
3980

10. United Nations (UN) Resolution, Transforming our world: the 2030 Agenda for Sustainable
Development, 2015 (A/RES/70/1).

3981

Additional references:3982

11. Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015.

3983

Resources:

3984
3985
3986

12. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
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16. World Benchmarking Alliance (WBA), Corporate Human Rights Benchmark methodology,
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