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

Item 02 – GRI Universal Standards
Project – Revised GRI 102: About theOrganization
For GSSB discussion
Date

26 February 2021

Meeting

23 March 2021

Project

GRI Universal Standards Project

Description

This document presents the revised draft of GRI 102: About the Organization
following the public comment feedback. Key changes are highlighted in commentboxes within the document. Minor editorial changes have not been highlighted, but
a draft tracking all changes to the text has been included in the Annex.
The public comments to this draft can be found here:
https://www.globalreporting.org/media/s0bbizo2/item-05-public-comments-torevisions-gri-102-in-the-universal-standards-exposure-draft.pdf

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

1

Contents
Explanatory note ................................................................................................................... 3
Revised GRI 102: About the Organization............................................................................. 4
Annex. Revisions with track changes .................................................................................. 35

Page 2 of 68

2

Explanatory note

3

The following significant revisions have been made in response to public comment feedback:

4
5
6
7

Section 2. Organizational details and reporting practices• Expanded Disclosure REP-3 for organizations to report the publication date of reported
information and retained the contact point for questions regarding the reported information,
see lines 100-101.

8
9
10
11
12

Section 3. Organizational activities• Separated the requirements on employees and other workers in two disclosures “ACT-2
Employees” and “ACT-3 Other workers” for clarity, see lines lines 270-288, and 369-382.
• Revised Disclosure ACT-2 to include information on non-guaranteed hour employees, which
has been identified as a gap, see line 277.

13

Section 5. Strategy, policies, and practices

14
15
16
17
18
19
20

•
•
•

Clarified in the introduction the difference between the disclosures in this section and thedisclosures in GRI 103, see lines 473-478.
Moved the requirement to report the date of approval of the policy commitments to theguidance section. This information is not essential, see lines 525-526.
Revised requirement on compliance with laws and regulations. This is to capture instancesthat may not be significant in their monetary value but have a significant impact, see lines
875-881.

21

Additional revisions made in response to public comment feedback are explained in comment boxes.

22
23

Other editorial revisions have been made to the text to improve clarity and consistency with the GRI
Style Guide and are explained in comment boxes.

Page 3 of 68

24

Revised GRI 102: About the25

Organization

26

Section 1. Introduction

27[under review]

28

Section 2. Organization and its

29reporting practices

30
31

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

32

Disclosure REP-1 Organizational details

33

Requirements

34

The organization shall:

35

a. report its legal name;36b. report its nature of ownership and legal form;

37c. report the location of its headquarters;

38

d. report its countries of operation.

39

Guidance

40

Guidance to REP-1-aThis requirement has been edited to align with thereporting approach in GRI 207: Tax.

41
42

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.

See also corresponding guidance in lines 51-55 thatclarifies the reporting expectation for this requirement.

43

Guidance to REP-1-b

Original wording: “countries where it has significant
operations”

44
45
46

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 charitable organization.

47

Guidance to REP-1-c

48
49

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

50

Guidance to REP-1-d

51
52
53

The organization can report specific locations within countries where it has operations, e.g., regions,states, or cities, if this provides contextual information about the scale of its activity and about the
impacts included in its sustainability reporting. If the organization has reported its countries ofCommented [SD1]: Type of change: editorial
revision.
The title of this section has been changed for clarity.
Original wording: “Organizational details and reporting
practices”

Commented [SD2]: Type of change: revision following
public comment feedback.

Page 4 of 68

54
55

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.

56
57

Disclosure REP-2 Organizational entities included in thesustainability reporting

58

Requirements

59

The organization shall:

60

a. list its entities that are included in its sustainability reporting;

61
62
63

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;64
65

c. if the organization consists of multiple entities, explain the approach used forconsolidating the information, including:Commented [SD3]: Type of change: revision following
public comment feedback.

66

i.

whether the approach involves adjustments to information for minority interests;

67
68

ii.

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

69

iii.

whether and how the approach differs across material topics.

The words “that form a consolidated group” have been
deleted to avoid confusion with the use of “consolidated
group” in financial standards and instruments.
Commented [SD4]: Type of change: editorial
revision.
The words “in the case of entities that are not wholly
owned” have been deleted as this information isrepetitive of the description of “minority interests” in theguidance.

70

Guidance

71

Guidance to REP-2-a

72
73
74
75
76

The entities reported under REP-2-a form the basis for reporting the disclosures in this Standard andfor identifying the organization’s material topics and related impacts. The organization should align theentities included in its sustainability reporting with the entities included in its other statutory andregulatory reporting, in particular, its financial reporting. See Section 5.1 of GRI 101: Using the GRI
Standards for more information.

77
78
79

When identifying its material topics and related impacts, the organization should consider the impactsof additional entities with which it has business relationships, that are not included in the list reported
under REP-2-a. See Section 2 of GRI 103: Material Topics for more information.

80

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

81
82
83

The organization can provide a reference or link to the list of entities included in its audited
consolidated financial statements or financial information filed on public record and specify which are
not included in its sustainability reporting.

84
85
86

If all entities are included in its sustainability reporting, a brief statement of this fact and a reference orlink to the list of entities included in its audited consolidated financial statements or financial
information filed on public record is sufficient to meet the requirements in REP-2-a and REP-2-b.

87
88

The organization can separately report any additional entities included in the sustainability reportingthat are not included in the organization’s financial reporting.

Commented [SD5]: Type of change: editorial revision.

89

Guidance to REP-2-c

New guidance added.

90
91

The consolidated information covers the parent entity and the entities it controls and has an interest insuch as subsidiaries, joint ventures, and affiliates.

92

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

Commented [SD6]: Type of change: revision following
public comment feedback.
Revised the guidance to ensure consistency with thedescription of joint ventures in other sections of the
Universal Standards (i.e., business partners rather thansubsidiaries).

Page 5 of 68

93

Disclosure REP-3 Reporting period and frequency

94

Requirements

95

The organization shall:

96

a. specify the reporting period for its sustainability reporting;

97
98
99

b. if the organization has audited consolidated financial statements or financial information
filed on public record, specify the reporting period for its financial reporting, and if it does
not align with the period for its sustainability reporting, explain the reason for this;100c. report the publication date and frequency of its sustainability reporting;101d. report the contact point for questions regarding the reported information.

102

Guidance

103

Guidance to REP-3-a and REP-3-b

104
105
106

The reporting period refers to the time period covered by the reported information (e.g., the year
ending 31 December 2021 or 1 July 2021 through 30 June 2022). The organization can specify thestart and end dates of the reporting period in the introduction of its report.

107
108
109

The organization should align the reporting period for its sustainability reporting with the reporting
period for its other statutory and regulatory reporting, in particular, its financial reporting. See Section
5.1 of GRI 101: Using the GRI Standards for more information.

110

Guidance to REP-3-c

111

The frequency of reporting refers to how often the organization carries out reporting (e.g., annually).

112

Disclosure REP-4 Restatements of information

113

Requirements

114

The organization shall:

115
116

a. report any restatements of information made from previous reporting periods, and explain
the reasons for such restatements and their effect.

117

Guidance118
119

This disclosure provides transparency on the reasons for restatements and their effects on thereported information.

120

Guidance to REP-4-a

121
122
123
124
125
126
127

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 business
context. Restatements of information provide consistency and enable comparability of information
between reporting periods, and help information users to interpret the reported information. See thereporting principle of Comparability in Section 4 of GRI 101: Using the GRI Standards for more
information.

128

Examples of reasons for restatements of information include:

Commented [SD7]: Type of change: revision following
public comment feedback.
Added the publication date for the reported information.

129•

a change of base periods or reporting periods;

130•change in the nature of the business;

131•

change in measurement methods;

Page 6 of 68

Commented [SD8]: Type of change: revision following
public comment feedback.
Retained the contact point.
Commented [SD9]: Type of change: editorial revision.
New guidance addded.

132
133

•

disposals, mergers, or acquisitions;•errors made in previous reporting periods.

134
135

The organization can report the criteria it uses to determine when a change or error in previously
reported information is considered significant enough to issue a restatement.

136
137
138

The effect of the restatement refers to the actual revision or correction made to previously reported
information. If the restatement relates to quantitative information, the organization should specify thequantitative change in the restated information.

139
140
141
142
143
144
145
146
147

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 reported emissions that meetsthe organization’s restatement criteria. The organization then restates its previously reported
information on GHG emissions in its reported information for the current period. In this case, theorganization is required to explain that it has restated its previously reported GHG emission levels dueto the new measurement methodology, and that this has resulted in lower GHG emissions thanpreviously reported for these periods. The organization should also report the quantitative change
observed (e.g., GHG emissions are 10% lower compared to the level of emissions previously
reported).

148

Disclosure REP-5 External assurance

149

Requirements

150

The organization shall:

151
152

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

153

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

154
155

i.

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

156
157
158

ii.

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

159

iii.

describe the relationship between the organization and the assurance provider.

Commented [SD10]: Type of change: revision
following public comment feedback.
New guidance added.

Commented [SD11]: Type of change: editorial
revision.
The wording of this requirement has been revised asconclusions or opinions are usually not publishedseparately from an assurance report or an assurance
statement.

160

Guidance

Original wording: “conclusions, or opinions;”

161

Guidance to REP-5-b-ii

Commented [SD12]: Type of change: revision
following public comment feedback.

162
163

If the assurance reports or statements include a description of what has been assured, and on what
basis, then a link to this information is sufficient to meet the requirement.

Removed reference to “what has not been assured” as
not meaningful or feasible for reporting.

164
165
166

If the assurance reports or statements do not include a description of what has been assured, and on
what basis, then the organization is required to report a summary of the key elements covered in theexternal assurance report. The summary should be written in accessible language and include:

See also corresponding guidance on lines 162-163.

167•

the scope of information and processes covered;168•

the assurance and reporting standards used;169•

the responsibilities of the organization relative to the assurance provider;170•

the level of assurance obtained;

171•

any limitations of the assurance process;172•

the opinion or conclusions formally signed off by the assurance provider;173•

a summary of the work performed; andPage 7 of 68

174

•

information on the experience and qualifications of the assurance providers.

175

See Section 5.2 of GRI 101: Using the GRI Standards for more information on external assurance.

176

Guidance to REP-5-b-iii

177
178
179

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

180
181

See Section 5.2 of GRI 101: Using the GRI Standards for more information on working withassurance providers.

Commented [SD13]: Type of change: revision
following public comment feedback.
New guidance added.

Page 8 of 68

182

Section 3. Activities and workers

183
184
185

The disclosures in this section provide an overview of the organization’s activities and of its
employees and other workers. This contextual information helps information users better understandthe nature of the organization and its impacts on the economy, environment, and people.

186
187

Disclosure ACT-1 Activities, value chain, and other business
relationships

188

Requirements

189

The organization shall:

190

a. report its sector;

191

b. describe its value chain, including:

192

i.

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

193
194

ii.

characteristics of the entities upstream from the organization and their activities
related to the organization’s products and services, i.e., its supply chain;

195
196

iii.

characteristics of the entities downstream from the organization and their activities
related to the organization’s products and services;

197

c. report other relevant business relationships;

198
199

d. describe significant changes in ACT-1-a, ACT-1-b, and ACT-1-c compared to the previous
reporting period.

200

Guidance

201

Guidance to ACT-1-a

202
203
204
205

Sectors can be identified according to different categories, such as the public or private sector, orindustry-specific categories such as the education sector or the financial sector. If the organization ispart of more than one sector, it can report those sectors that provide contextual information tounderstand its impacts on the economy, environment, and people.

206
207
208
209
210

Depending on the organization’s activities, sectors can be identified using various classification
systems that define categories for economic activities. For example, the UN-based International
Standard Industrial Classification of All Economic Activities [Ref no.], or investment-basedclassification systems such as the Global Industry Classification Standard or the Industry
Classification Benchmark [Ref no.].

211

Guidance to ACT-1-b

212
213
214
215
216
217

The organization’s value chain includes the organization’s own activities, as well as activities carriedout by entities upstream and downstream from the organization related to the organization’s products
and services. Entities upstream from the organization are those that supply products or services thatare used in the development of the organization’s own products or services. Entities downstream fromthe organization receive products or services from the organization. Entities in the value chain include
entities beyond the first tier, both upstream and downstream.

218
219
220
221

The information required in ACT-1-b provides contextual information to understand the organization’s
impacts across its value chain, including through the use of its products and services. Describing themarkets served provides further information on the groups of customers targeted by the organization’s
products and services.

Commented [SD14]: Type of change: editorial
revision.
The title of this section has been changed for clarity.
Original wording: “Organizational activities”

Commented [SD15]: Type of change: revision
following public comment feedback
Removed “main” from the formulation of therequirement for clarity.
See also corresponding guidance at lines 223-224.
Original wording: “organization’s main activities”

Page 9 of 68

222

Guidance to ACT-1-b-i

223
224
225
226

ACT-1-b-i does not require a detailed description of each activity of the organization. Instead, theorganization can provide a high-level overview of all its activities. The organization should report its
total number of operations and explain how it defines ‘operation’. When describing its products andservices, the organization should:

227•

report the quantity of products or services provided during the reporting period;

228
229
230

•

report if any of its products or services are banned in certain markets or are the subject of
stakeholder concerns or public debate, and how the organization has responded to theseconcerns.

231

When describing the markets, the organization can:232•

report the geographic, demographic, or other characteristics of the markets;

233
234

•

report information on the size and relative importance of the markets, for example, net salesor net revenues.

235

Guidance to ACT-1-b-ii

236

The organization can describe:237•

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

238
239

•

the estimated number of suppliers throughout its supply chain (in the first tier, second tier,etc.);

240
241•

the types of activities of its suppliers (e.g., manufacturing the organization’s products,
providing services);

242
243

•

the nature of its business relationship with its suppliers (e.g., long-term or short-term,
contractual or non-contractual., project-based or event-based);244•

the sector-specific characteristics of its supply chain (e.g., labor-intensive);245•

the estimated monetary value of payments made to its suppliers;

246•

the geographic locations of its suppliers.

247

Guidance to ACT-1-b-iii

248

The organization can describe:

249
250

•

the types of customers and beneficiaries (e.g., end consumers, other businesses, recipientsof the products or services from a social enterprise or a nonprofit organization);251•

the estimated number of downstream entities (in the first tier, second tier, etc.);

252•

the types of activities of the downstream entities (e.g., wholesalers, manufacturers, retailers);

253
254

•

the nature of its business relationship with the downstream entities (e.g., long-term or shortterm, project-based or event-based);255•

the geographic locations of the downstream entities.

256

Guidance to ACT-1-c

257
258
259

Other relevant business relationships include relationships that the organization has with entities thatare not described as part of its value chain under ACT-1-b. These consist of business partners (e.g.,
joint ventures) and other entities directly linked to the organization’s operations, products, or services.

260
261

When describing other relevant business relationships, the organization can report the types ofentities, their activities, and their geographic location.

262

Guidance to ACT-1-d

263
264

ACT-1-d requires the organization to describe significant changes in its sector, value chain, and otherbusiness relationships compared to the previous reporting period. This information can help explain

Page 10 of 68

265
266
267
268

variations in the organization’s impacts included in its sustainability reporting. 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, or changes in the locations of its suppliers.

269

Disclosure ACT-2 Employees

270

Requirements

271

The organization shall:

272
273

a. report the total number of employees, and a breakdown of this total by gender and byregion;274

b. report the total number of:275

Commented [SD16]: Type of change: editorial
revision.
The requirements on employees and other workers
have been separated in two disclosures “ACT-2
Employees” and “ACT-3 Other workers” for clarity.

i.

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

276

ii.

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

277

iii.

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

278

iv.

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

279

v.

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

280
281

c. provide contextual information to understand the data reported under ACT-2-a and ACT-2b;

282
283

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

284
285

e. describe the assumptions and methodologies used to compile the data, including whether
the number of employees are reported:

286

i.

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

287
288

ii.

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

289

Guidance

290291This disclosure requires information on the number of employees that perform work for theorganization.

292
293
294
295
296

This disclosure, together with Disclosure ACT-3 on workers who are not employees, gives insight into
the organization’s approach to employment, as well as the scope and nature of impacts arising from
employment practices. It also provides contextual information that helps understand the information
reported in other disclosures, and it serves as the basis for calculation in several disclosures, such as
the disclosure on the percentage of employees covered by collective bargaining agreements.

297
298

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

299

See references 6, 7, 8, 16, 22, 25, and 27 in the Bibliography section.

300

Guidance to ACT-2-a

301
302

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

303
304

Providing a breakdown of employees by gender gives insight into gender representation and diversity
across an organization. Providing a breakdown of employees by region gives insight into regional

Page 11 of 68

Commented [SD17]: Type of change: revision
following feedback from the labor expert group andeditorial revision.
This requirement has been revised to include the nonguaranteed hours employees, who were not accounted
for in the other categories of employees. See also
guidance at lines 314-318
The terms “employment contract” and “employment
type” have been deleted from the disclosures and the
GRI Glossary. Instead the terms “permanent
employee”, “temporary employee”, “full-time employee”,“part-time employee”, “non-guaranteed hours
employee” are used separately.
Original wording: “The organization shall:a. report the total number of, and provide abreakdown of this total by:i. employment contract (permanent andtemporary), by gender;ii. employment contract (permanent andtemporary), by region;iii. employment type (full-time and part-time), by
gender;iv. employment type (full-time and part-time), byregion;”305
306

representation and variations. Region can refer to a country or to other geographical areas like cities
and world regions.

307

See Tables 1-2 for examples of how to present this information.

308

Guidance to ACT-2-b

309
310
311
312
313

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

314
315
316
317
318

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

319
320
321

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 1000, to the nearest
100.

322

See Tables 1-2 for examples of how to present this information.

323

Guidance to ACT-2-c

324
325
326
327
328
329

Quantitative data, such as the number of temporary or part-time employees is unlikely to provide
sufficient information on 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 a voluntary choice. For this reason, quantitative data should beaccompanied by contextual information to help information users formulate an appropriate
interpretation of the data.

330
331
332
333
334

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

335
336
337
338
339

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 in the different
regions. Further, the organization can explain the reasons for part-time employment. Examples ofsuch reasons could be to accommodate employees’ requests to work reduced hours, or because theorganization is unable to provide full-time employment to all employees.

340
341
342

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.

343

Guidance to ACT-2-d

344
345
346

It is up to the organization to determine which fluctuations in the number of employees it considers
significant to report under this disclosure. The organization should report its threshold for identifying
significant fluctuations.

347
348
349
350
351

The description can include how the numbers vary, i.e., whether the numbers have increased or
decreased during the reporting period or in comparison to the previous reporting period. It can also
include the reasons for the fluctuations. For example, an increase in the number of employees during
the reporting period could be due to a seasonal event. A decrease in the number of employees incomparison to the previous reporting period could be due to the completion of a temporary project.

352
353

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.

Page 12 of 68

Commented [SD18]: Type of change: editorial
revision.
New guidance added.

Commented [SD19]: Type of change: editorial
revision.
New guidance added.

354

Guidance to ACT-2-e

355
356
357

The organization should report the total number of employees and the number of full-time and parttime employees in head count. The head count gives insight into the number of individual employees
performing work for the organization, whether on a full-time or part-time basis.

358
359
360

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

361

The organization can also use another methodology for reporting these numbers.

362
363
364

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.

365

Table 1 Example template for presenting information on employees by gender

Commented [SD20]: Type of change: editorial
revision.

[Reporting period]

The tables have been revised to reflect the changes in
the requirements.

Number of employees [head count]
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]

Page 13 of 68

Male[Number]

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

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]Number of part-time employees [head count]

366

Total

[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]* as specified by the employees

Page 14 of 68

367

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

Region A[Number]

Region B[Number]Number of part-time employees [head count]
Total[Number]

Region A[Number]

Region B[Number]

Page 15 of 68368

Disclosure ACT-3 Workers who are not employees

369

Requirements

370

The organization shall:

371
372

Commented [SD21]: Type of change: revision
following feedback from the labor expert group.
Separated “workers who are not employees” from
“employees” for clarity.

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

373
374

i.

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

375

ii.

the work they perform;

376
377

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

378
379

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

380

i.

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

381
382

ii.

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

383

Guidance

384
385
386
387
388
389

This disclosure requires information on the number of workers who are not employees and whose
work is controlled by the organization. The information is important in order to understand how many
workers in total perform work for the organization, because workers who are not employees are notrepresented in employment figures reported under Disclosure ACT-2. This disclosure provides anunderstanding of how much the organization relies on workers who are not employees to perform its
work compared to employees.

390
391
392
393

This disclosure, together with Disclosure ACT-2 on employees, 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 helps understand the information reported inother disclosures.

394
395

This disclosure covers all workers who are not employees and who perform work for any of theorganization’s entities included in its sustainability reporting (reported under Disclosure REP-2).

396

See references 8, 20, 22, 23, 24, 26, and 31 in the Bibliography section.

397

Guidance to ACT-3-a

398
399

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

400
401
402

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.

403
404
405
406

Workers who are not employees and whose work is controlled by the organization can work for theorganization or for the organization’s suppliers, customers, or other business partners, such as joint
ventures. Types of such workers can include agency workers, apprentices, contractors, home
workers, interns, self-employed persons, sub-contractors, or volunteers.

407
408

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

Page 16 of 68

409
410
411
412
413
414
415
416
417
418
419
420
421
422

•
•
•

Contractors hired by the organization to perform work at the organization’s workplace, in a
public area (e.g., on a road, on the street), or directly at the workplace of the organization’sclient;Workers of the organization’s supplier , where the organization instructs the supplier to use
particular materials or work methods in manufacturing the products or delivering the services.
Volunteers or interns performing work for the reporting organization.

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

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;
Workers of a supplier contracted by the organization who work using the supplier’s work
methods, such as when the organization sources products from a supplier, and these arestandard products of the supplier.

423
424
425

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 1000, to the nearest 100.

426
427
428

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 withrequirement.

429

Guidance to ACT-3-a-i and ACT-3-a-ii

430
431
432
433

ACT-3-a-i requires the organization to report the most common types of worker who are not
employees. The organization is also required to report its contractual relationship with the mostcommon types of worker, i.e., whether it engages them directly or it engages them indirectly through athird party, and in the latter case, who this third party is (e.g., employment agency, contractor).

434
435

ACT-3-a-ii requires the organization to describe the work performed by the most common types ofworker.

436
437
438

It is sufficient if 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.

439

Guidance to ACT-3-b

440
441
442

It is up to the organization to determine which fluctuations in the number of workers it considers
significant to report under this disclosure. The organization should report its threshold for identifying
significant fluctuations.

443
444
445
446
447
448

The description can include how the numbers vary, i.e., whether the numbers have increased or
decreased during the reporting period or in comparison to the previous reporting period. It can also
include the reasons for the fluctuations. For example, an increase in workers who are not employees
during the reporting 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 completionof a temporary project.

449
450
451

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.

452

Guidance to ACT-3-c

453
454
455
456

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 also
use another methodology for reporting these numbers.

457
458

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

Page 17 of 68

Commented [SD22]: Type of change: editorial
revision.
New guidance added.

Commented [SD23]: Type of change: editorial
revision.
New guidance added.

459
460

these numbers in averages across the reporting period takes into account fluctuations during thereporting period.

461

Section 4. Governance[Under review]462

Section 5. Strategy, policies, and463

practices

Commented [SD24]: Type of change: editorial
revision.

464
465
466

The disclosures in this section provide an overview of an 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.

The title of this section has been changed as
disclosures in other sections of GRI 102 and otherStandards also deal with aspects of responsible
business conduct.

467
468
469
470
471
472

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 regard combating bribery, bribe
solicitation, extortion, and other forms of corruption; and adhering to good tax practices. In addition,
they include conducting due diligence in order to identify, prevent, mitigate, and account for how anorganization addresses its negative impacts on the economy, environment, and people.

473
474
475
476
477
478

The disclosures in this section require information about the organization’s policies and practices forresponsible business conduct generally rather than for its material topics specifically. Disclosure MT-3
in GRI 103: Material Topics requires information about how the organization manages each material
topic. If the organization has described its policies and practices for a material topic under thedisclosures in this section, it can provide a reference to this information under MT-3 and does notneed to repeat the information.

Commented [SD25]: Type of change: revision
following public comment feedback.
New text added to clarify the difference between thedisclosures in this section and the disclosures in GRI
103.

1

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

Page 18 of 68479

Disclosure SPP-1 Statement on sustainable development strategy

480

Requirements

481

The organization shall:

482
483
484

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

485

Guidance

486

Guidance to SPP-1

487

The organization should describe:

488
489
490

•

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

491
492

•

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

493
494
495

•

its short and medium-term strategic priorities for contributing to sustainable development,
including the relation to and observance of internationally recognized standards andagreements;

496
497

•

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

498
499

•

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

500
501

•

a view of performance against goals and targets for the organization’s material topics that
contributed to sustainable development during the reporting period;

502
503

•

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

504
505
506

When determining whether the highest governance body or most senior executive reports therequired statement, the organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which could be related to:507•

the country where the organization is incorporated or registered;508•

a stock exchange where the organization trades its securities;

509
510

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

Commented [SD26]: Type of change: editorial
revision (change in location).
Requirement “g” has been removed as this will apply to
all disclosures in the GRI Standards. This will be
explained in GRI 101: Using the GRI Standards.

511

Disclosure SPP-2 Policy commitments

512

Requirements

513

The organization shall:

514

a. describe its policy commitments for responsible business conduct, including:Original wording: “g. if the organization does not haveany of the policy commitments in RBC-2-a, explain thereason for not having them or describe any plans todevelop them.”

515

i.

the authoritative intergovernmental instruments that the commitments reference;

516

ii.

whether the commitments stipulate conducting due diligence;

517

iii.

whether the commitments stipulate applying the precautionary principle;

Commented [SD27]: Type of change: editorial
revision.
Original wording: “internationally recognized
instruments”

Page 19 of 68

The term “authoritative intergovernmental instruments”
is now used consistently throughout the GRI Standards.

518
519

iv.

whether the commitments stipulate respecting human rights;

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

520

i.

the internationally recognized human rights that the commitment covers;

521
522

ii.

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

523
524

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

525
526

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

527
528

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

529
530

f.

531

Guidance532

Background

533
534
535
536

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.

537
538
539
540

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

541

Guidance to SPP-2-a

542
543

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

544
545

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

546

Guidance to SPP-2-a-i

547
548

See the Bibliography section for a list of authoritative intergovernmental instruments for responsible
business conduct.

549

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

550

Guidance to SPP-2-a-iii

551
552
553
554

The precautionary principle is set out in Principle 15 of the UN Rio Declaration on Environment andDevelopment. 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.’

555
556
557

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.

558
559
560

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.

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

Commented [SD28]: Type of change: revision
following public comment feedback.
The requirement to report the date of approval of thepolicy commitments has been moved to the guidance
section, see lines 601-602, as this information is notessential.
Original wording: “report the level at which each of thepolicy commitments was approved within theorganization, including whether this is the most seniorlevel, and the date of approval;”

Page 20 of 68

Commented [SD29]: Type of change: editorial
revision.
The wording of this requirement has been simplified forclarity and for ease of translation.
Original wording: “report whether the policy
commitments apply solely to the organization’s own
activities or whether they also stipulate theorganization’s expectations of those with which it has
business relationships and, if so, describe what those
expectations are;”See also corresponding guidance at lines 603-615.

561
562
563

The application of the precautionary principle can be reported under MT-3-d-i in GRI 103: Material
Topics, as part of the organization’s actions to prevent or mitigate potential negative impacts for eachmaterial topic.

564

Guidance to SPP-2-b-i

565
566
567

Human rights are rights inherent to all human beings, regardless of nationality, place of residence,
sex, national or ethnic origin, color, religion, language, or any other status. These rights are allinterrelated, interdependent, and indivisible.

568
569
570

The internationally recognized human rights include, at a minimum, the rights set out in the UN
International Bill of Human Rights and the principles concerning fundamental rights set out in the ILO
Declaration on Fundamental Principles and Rights at Work.

571
572
573
574

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 and theirfamilies. There are also standards of international humanitarian law that apply in situations of armed
conflict, such as the International Committee of the Red Cross (ICRC) Geneva Conventions of 1949.2

575
576

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

577
578
579
580
581
582

If the policy commitment covers all internationally recognized human rights, a brief statement of thisfact is sufficient to meet the requirement. The organization can also state if the policy commitment
references certain rights that require particular attention. For example, it 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.

583
584
585

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

586

Guidance to SPP-2-b-ii

587
588
589
590
591
592
593

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

594
595
596

For example, a bank might give particular attention in its policy commitment to avoid discriminating
against specific categories of customers, or a mining company might give particular attention to avoid
infringing on the rights of indigenous peoples.

597

Guidance to SPP-2-d

598
599
600

The most senior level may differ between organizations. For example, the most senior level in theorganization could be the highest governance body (e.g., the board), or it could be the most senior
executive (e.g., chief executive officer).

601
602

The organization can also report the dates of approval and adoption of the policy commitments, andhow frequently the commitments are reviewed.

Commented [SD30]: Type of change: revision
following public comment feedback.
New guidance added.

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 6
May 2020.
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 6 May 2020.

Page 21 of 68

Commented [SD31]: Type of change: editorial
revision (change in location).
This content was previously located under the definitionof “internationally recognized human rights” in the
Glossary.
This change has been implemented to maintain aconsistent Glossary style of limited notes that are usedprimarily for essential clarifications. Detailed
explanations are more helpful to users when reading
the disclosure guidance sections.

Commented [SD32]: Type of change: editorial
revision.
This list has been organized in alphabetical order.
For conciseness, the examples “(e.g., lesbian, gay,bisexual, transgender, intersex)” have been moved tothe definition of “vulnerable group” in the Glossary,
which now includes a more extensive list of examples ofvulnerable groups.

603

Guidance to SPP-2-e

604
605

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 meet the requirement.

606
607
608
609

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 and it can additionally explain why the commitments are limited
to these activities.

610
611
612
613
614
615

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), and it can additionally explain why thecommitments are limited 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.

616

Guidance to SPP-2-f

617

The organization can report:

618
619

•

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;

620
621

•

the means through which it communicates the policy commitments (e.g., newsletters, formal
or informal meetings, dedicated websites, contractual agreements);

622
623

•

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).

Commented [SD33]: Type of change: editorial
revision.

624

Disclosure SPP-3 Embedding the policy commitments

625

Requirements

626

The organization shall:

627
628

a. describe how the organization embeds each of its policy commitments for responsible
business conduct throughout its activities and business relationships, including:

The wording of this disclosure title has been shortened.
Original wording: “Embedding the policy commitments
throughout the organization”

629
630

i.

how it allocates responsibility to implement the commitments across different
levels within the organization;

631
632

ii.

how it integrates the commitments into organizational strategies, operational
policies, and operational procedures;

633

iii.

how it implements its commitments in its business relationships;

634

iv.

training that the organization provides on implementing the commitments.

Commented [SD34]: Type of change: editorial
revision.
The wording of this requirement has been simplified forclarity and for ease of translation.

635

Guidance636

Background

637
638
639
640

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.

641

Guidance to SPP-3-a-i

642
643

Examples of different levels within an organization include the highest governance body, senior
executives, and operational levels.

644

The organization can report:

Page 22 of 68

Original wording: “how the organization works withthose with which it has business relationships, toimplement the commitments;”

645
646

•

the most senior level with oversight of, or accountability for, the implementation of the policy
commitments;

647
648
649

•

the functions in the organization with day-to-day responsibility for implementing each of thepolicy commitments (e.g., human resources with the responsibility to implement thecommitment to respect the rights of workers), including:

650
651

-

their reporting lines to senior decision-making levels;-

the reason for allocating the responsibility to them;

652
653

•

whether responsible business conduct is formally discussed at meetings of the highest
governance body or senior executives and, if so, which topics are discussed;

654
655
656

•

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).

657

Guidance to SPP-3-a-ii

658

The organization can describe:659•

how it aligns the policy commitments with its:

660-

broader risk management systems and management policies;

661
662

-

environmental, socioeconomic, and human rights impact assessments, and other due
diligence processes;

Commented [SD35]: Type of change: editorial
revision.

663
664

-

policies and procedures that set financial and other performance incentives for
management or workers;

Changes made for consistency with the corresponding
guidance in Section 2 of GRI 103: Material Topics.

665
666

•

how it applies the policy commitments when making decisions, such as about its sourcing andoperating locations;

667
668
669

•

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.

670

Guidance to SPP-3-a-iii

671

The organization can describe:

672
673

•

Commented [SD37]: Type of change: revision
following public comment feedback.

674
675
676

-

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;

677
678

-

whether and how it considers the policy commitments in contracting or investment
agreements, or in specific policies or codes of conduct for suppliers;

679
680

-

whether and how it considers the policy commitments in the process of determining
whether to initiate, continue, or terminate a business relationship;

681
682

•

processes through which it enables or supports business partners and other parties toimplement the policy commitments (e.g., capacity building, peer sharing);

683
684

•

incentives that it offers to business partners and other parties to implement the policy
commitments (e.g., price premiums, increased orders, long-term contracts).

Guidance to SPP-3-a-iv

686

The organization can report:687•

the content of the training;688•

to whom the training is provided, and whether it is mandatory;689•

the form (e.g., in-person, online) and frequency of the training;

Commented [SD36]: Type of change: revision
following public comment feedback.
Example added.

its procurement or investment policies and practices, and its engagement with those withwhich it has business relationships, including:685

Original wording: “environmental and social impact orrisk assessments”

Page 23 of 68

New guidance added.

690

•

examples of how the organization has determined that the training is effective.

691
692
693

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).

694
695
696
697
698
699

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). In addition, the organization can report the
number or percentage of workers, business partners, and other parties that have been trained during
the reporting period.

700
701

Disclosure SPP-4 Grievance mechanisms and other remediation
processes

702

Requirements

703

The organization shall:

704
705

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;706

b. describe its approach to identify and address grievances, including:

707

i.

the grievance mechanisms that the organization has established or participates in;

708
709

ii.

other processes by which the organization provides for or cooperates in theremediation of negative impacts that it identifies it has caused or contributed to;

710
711
712

c. describe how the stakeholders who are the intended users of the grievance mechanisms
and other remediation processes are involved in the design, review, operation, andimprovement of these mechanisms and processes;

713
714
715

d. describe how the organization tracks the effectiveness of the grievance mechanisms andother remediation processes, and report examples of their effectiveness, including
stakeholder feedback.

716

Guidance

717

Background

718
719
720
721

This disclosure covers grievance mechanisms and other remediation processes that the organization
has established or participates in. These mechanisms and processes enable stakeholders to raise
concerns about, and seek remedy for, the organization’s actual and potential negative impacts onthem. This includes impacts on their human rights.

722
723
724
725
726
727
728

The UN Guiding Principles on Business and Human Rights and the OECD Guidelines forMultinational Enterprises set out expectations for organizations to provide for or cooperate in theremediation, through legitimate processes, of negative impacts that they identify they have caused orcontributed to. An organization is not responsible for providing remediation for negative impacts thatare directly linked to its operations, products, or services by its business relationships, but it can playa role in providing it. See Box 3 in GRI 103: Material Topics for more information on causing,
contributing, or being directly linked to negative impacts.

729
730

These instruments also set out expectations for organizations to establish or participate in effective
operational-level grievance mechanisms.

731
732
733
734

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 to be reported under Disclosure SPP-5.

Page 24 of 68

Commented [SD38]: Type of change: editorial
revision.
Changes made for consistency with requirement SPP2-f on how the policy commitments are communicated.
Original wording: “individuals”

Commented [SD39]: Type of change: revision
following public comment feedback.
New clarification added.

735

Guidance to SPP-4

736
737
738
739
740

This disclosure covers the operation of grievance mechanisms and other remediation processes thatthe organization has established or participates in to enable stakeholders to raise concerns about theorganization’s actual and potential negative impacts on them. The actions taken to provide for orcooperate in the remediation of actual negative impacts for material topics are to be reported underMT-3-d-ii in GRI 103: Material Topics.

741
742
743
744
745
746

The disclosure does not cover environmental remediation processes, such as processes to remove
contaminants from soil, when these are not connected to grievances raised by stakeholders.
However, the remedy provided to stakeholders through the mechanisms and processes covered bythis disclosure could involve environmental remediation. The use of environmental remediation
processes to address actual negative impacts for material topics can be reported under MT-3-d-ii in
GRI 103: Material Topics.

747

Guidance to SPP-4-b-i

748
749

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.

750
751
752
753

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.

754
755
756
757
758

Non-state-based grievance mechanisms include those administered by the organization, either alone
or together with stakeholders, such as operational-level grievance mechanisms. It also includes
collective bargaining and the mechanisms established by collective bargaining, as well asmechanisms administered by industry associations, international organizations, civil society
organizations, or multi-stakeholder groups.

759
760
761
762
763

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.

764

The organization can describe:

765
766
767
768
769
770

•

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 anda separate hotline for workers to raise concerns about issues affecting their rights, such as
health and safety conditions;771•

how the mechanisms operate and who administers them (the organization or another party);

772
773
774

•

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 suchcase, how information from these mechanisms is centralized;

775
776
777

•

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;778•

the process through which grievances are investigated;

779•

whether grievances are communicated to the highest governance body;780•

whether grievances are treated confidentially;

781
782

•

whether the mechanisms can be used by stakeholders anonymously through representation
by a third party;

783
784

•

whether the organization requires or provides incentives for the creation or improvement ofoperational-level grievance mechanisms in workplaces of suppliers;

Commented [SD40]: Type of change: revision
following public comment feedback.

Page 25 of 68

New guidance added.

785
786
787

•

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.

788

Guidance to SPP-4-b-ii

789

SPP-4-b-ii covers remediation processes other than grievance mechanisms.

790
791
792

Examples include a customer service desk where customers raise complaints about discrimination or
privacy issues and receive remedy, or 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.

793

See Guidance to SPP-4-b-i for more information on how to describe other remediation processes.

794

Guidance to SPP-4-c

795
796
797

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.

798

Guidance to SPP-4-d

799
800
801
802
803

According to UN Guiding Principle 31, 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.

804

The organization can report:

805
806

•

whether and how the intended users are informed about the grievance mechanisms andremediation processes;

807
808

•

whether and how the intended users are trained on how to use the grievance mechanisms
and remediation processes;

809
810
811

•

the accessibility of the grievance mechanisms and remediation processes, such as thenumber of hours per day or days per week they are available, and their availability in different
languages;

812
813

•

how the organization seeks to ensure it respects users’ human rights and protects themagainst reprisals (i.e., non-retaliation for raising complaints or concerns);

814
815

•

how satisfied users are with the grievance mechanisms and remediation processes, and withthe resulting outcomes, as well as how the organization assesses user satisfaction;

816
817
818

•

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;819•

the number of grievances filed during the reporting period that are repeated or recurring;

820
821

•

changes made to the grievance mechanisms and remediation processes in response tolessons learned about their effectiveness.

822
823
824
825

Quantitative information, 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 aid in understanding and interpreting the quantitative information.

Page 26 of 68

Commented [SD41]: Note: This section is under review
by the Human Rights Technical Committee, following
public comment feedback that it was not clear by acustomer service desk is not a grievance mechanism.

Commented [SD42]: Type of change: editorial
revision.
Changes made for consistency with the corresponding
guidance in Section 2 of GRI 103: Material Topics.
Original wording: “how the organization seeks to ensurethat users are treated with respect and protectedagainst reprisals (i.e., non-retaliation for raisingcomplaints or concerns);”

827

Disclosure SPP-5 Mechanisms for seeking advice and raisingconcerns

828

Requirements

829

The organization shall:

830

a. describe the mechanisms for individuals to:

826

831
832

i.

seek advice on implementing the organization’s policies and practices forresponsible business conduct;

833

ii.

raise concerns about the organization’s responsible business conduct.

834

Guidance

835

Background

836
837
838
839
840

This disclosure covers an 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.

841
842
843
844
845

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 actual and potential
negative impacts on them. Grievance mechanisms are to be reported under Disclosure SPP-4.

846

Guidance to SPP-5

847
848
849
850

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.

851

Guidance to SPP-5-a

852

The organization can report:

853•

who the intended users of the mechanisms are;

854
855

•

how the mechanisms operate and which level or function in the organization is assigned
responsibility for them;

856
857

•

whether the mechanisms are operated independently of the organization (e.g., by a third
party);

858•

the process through which concerns are investigated;859•

whether requests for advice and concerns raised are treated confidentially;•

whether the mechanisms can be used anonymously.

860
861

Additionally, the organization can report on the effectiveness of the mechanisms, including:

862
863

•

whether and how the intended users are informed about the mechanisms and trained on how
to use them;

864
865

•

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;

866
867

•

how the organization seeks to ensure it respects users’ human rights and protects themagainst reprisals (i.e., non-retaliation for reporting concerns);

Page 27 of 68

Commented [SD43]: Type of change: editorial
revision.
Changes made for consistency with the corresponding
guidance in Section 2 of GRI 103: Material Topics.
Original wording: “how the organization seeks to ensurethat users are treated with respect and protectedagainst reprisals (i.e., non-retaliation for reporting
concerns);”

868

•

how satisfied users are with the mechanisms and with the resulting outcomes;

869
870

•

the number and types of requests for advice received during the reporting period, and thepercentage of requests that were answered;

871
872

•

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.

Commented [SD44]: Type of change: revision
following public comment feedback.

873

Disclosure SPP-6 Compliance with laws and regulations

874

Requirements

875

The organization shall:

876
877

a. report the total number of significant instances of non-compliance with laws or regulations
during the reporting period, with a breakdown of this total by:

878

i.

instances for which fines were incurred and their monetary value;

879

ii.

instances for which non-monetary sanctions were incurred;

Revised the disclosure to improve the proxy for
capturing instances of non-compliance. ‘Significance’ is
now not exclusively based on monetary value andorganizations are required to explan how they havedetermibed the threshold for significant insatnces of
non-compliance.
See also corresponding guidance on lines 913-923.

880

b. describe the significant instances of non-compliance;881

c. describe how it has determined significant instances of non-compliance.

882

Guidance883

Background

884
885

This disclosure addresses non-compliance, or failure to comply with, laws and regulations related toeconomic, environmental, and social matters that are applicable to the organization.

886
887

These laws and regulations can be issued by a variety of bodies including governments (local,
regional, and national), regulatory authorities, and public agencies.

888

Laws and regulations include:889•

international declarations, conventions, and treaties;890•

national, subnational, regional, and local regulations;

891
892

•

binding voluntary agreements made with regulatory authorities and developed as a substitutefor implementing a new regulation;

893
894
895

•

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.

896
897
898

Laws and regulations relating to economic and social matters include topics such as accounting andtax fraud, bribery, corruption, competition, the provision of products and services, or labor issues,
such as workplace discrimination.

899
900

Laws and regulations relating to environmental matters include topics such as biodiversity, emissions,energy, material use, spills and leaks, waste, and water and effluents.

901
902

Non-compliance with laws and regulations can give insight into the ability of management to ensurethat the organization conforms to certain performance parameters.

Page 28 of 68

903

Guidance to SPP-6-a

904
905

The scope of this disclosure includes instances of non-compliance that resulted in administrative or
judicial sanctions during the reporting period.

906
907
908

Non-monetary sanctions include restrictions imposed by governments, regulatory authorities, or publicagencies on the organization’s activities or operations, such as withdrawal of trading licenses or
licenses to operate in highly regulated industries.

909
910

The organization can include fines that have been reported in its audited consolidated financial
statements or in the financial information filed on public record.

911
912

If the organization has not incurred any fines or non-monetary sanctions for non-compliance with laws
or regulations, a brief statement of this fact is sufficient to meet the requirement.

913

Guidance to SPP-6-b

914
915
916
917

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, i.e., economic, environmental, or
social matters applicable to the organization. The organization should report sufficient information forstakeholders to understand the type and context of the significant instances of non-compliance.

918

The organization can explain whether the significant instances are repeated or recurring.

919

Guidance to SPP-6-c

920
921

When describing how the organization has determined significant instances of non-compliance, it can
include:922•

the severity of the impact resulting from the instance;

923•

external benchmarks used in its sector to determine significant instances of non-compliance.

924

Disclosure SPP-7 Membership associations

925

Requirements

926

The organization shall:

927
928

a. report industry associations, other membership associations, and national orinternational advocacy organizations in which it participates in a significant role.

929

Guidance

930

Guidance to SPP-7

931
932
933
934
935

The organization could 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. It could also apply 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 29 of 68

Commented [SD45]: Type of change: editorial
revision.
Added new guidance.

936

Section 6. Stakeholder engagement

937
938

This section includes disclosures on the organization’s stakeholder engagement practices, including
how it engages in collective bargaining with employees.

939

Disclosure SE-1 Approach to stakeholder engagement

940

Requirements

941

The organization shall:

942

a. describe its approach to engaging with stakeholders, including:

943

i.

the categories of stakeholders it engages with, and how they are identified;

944

ii.

the purpose of the stakeholder engagement;

945

iii.

how the organization seeks to ensure meaningful engagement with stakeholders.

946

Guidance

947

Guidance to SE-1

948
949
950

Stakeholders are individuals or groups that have interests that are affected or could be affected by theorganization’s activities. For more information on stakeholders, see Section 2.4 in GRI 101: Using the
GRI Standards.

951
952

This disclosure covers stakeholder engagement undertaken by the organization as part of its ongoing
activities rather than specifically for the purpose of sustainability reporting.

953

Guidance to SE-1-a-i

954
955
956
957

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.

958
959

The organization can explain how it determines which categories of stakeholders to engage with andwhich categories not to engage with.

960

Guidance to SE-1-a-ii

961
962
963
964

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.

965

The organization can also report:

966
967

•

the type of stakeholder engagement (e.g., participation, consultation, information) and its
frequency (e.g., ongoing, quarterly, annually);

968
969
970

•

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;

971
972
973

•

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;974•

the resources (e.g., financial or human resources) allocated to stakeholder engagement.

Page 30 of 68

Commented [SD46]: Type of change: revision
following public comment feedback.
Original wording: “the type and frequency (e.g.,annually, quarterly) of stakeholder engagement. For
example, whether the engagements are ongoing (e.g.,in the case of systemic issues) or whether they are
specific engagements with particular groups or forparticular operations or projects;”

975
976
977
978

Further information on stakeholder engagement undertaken for specific activities, such as setting up
and operating grievance mechanisms and other remediation processes, or determining and managing
material topics, is reported under other disclosures (SPP-4-d in this Standard, and MT-1-a-iii and MT3-f in GRI 103: Material Topics).

979

Guidance to SE-1-a-iii

980
981
982
983
984

Meaningful stakeholder engagement is, according to the Organisation for Economic Co-operation andDevelopment (OECD) Due Diligence Guidance for Responsible Business Conduct, characterized by
two-way communication and depends on the good 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.

985

The organization can report:

986
987

•

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);

988
989

•

how it engages with at-risk or vulnerable groups (e.g., whether it takes specific approaches
and gives special attention to potential barriers);

990
991

•

how it provides stakeholders with information that is understandable and accessible throughappropriate communication channels;

992
993

•

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;

994
995

•

how it seeks to respect the human rights of all stakeholders engaged, such as their rights to
privacy, freedom of expression, and peaceful assembly and protest;

996
997
998

•

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.

999

Disclosure SE-2 Collective bargaining agreements

1000

Requirements

1001

The organization shall:

1002

a. report the percentage of total employees covered by collective bargaining agreements;

1003
1004
1005
1006

b. for employees not covered by collective bargaining agreements, report whether it
determines their working conditions and terms of employment based on collective
bargaining agreements that cover its other employees or based on collective bargaining
agreements from other organizations.

1007

Guidance

1008
1009

The right to collective bargaining is a fundamental right at work that is covered in the ILO Right toOrganise and Collective Bargaining Convention [Ref no. 9].

1010
1011
1012
1013
1014
1015

Collective bargaining refers to negotiations that take place between one or more employers or
employers' organizations and one or more workers' organizations (trade unions). The objective of
these negotiations is to reach a collective agreement on working conditions and terms of employment(e.g., wages and working time) and to regulate relations between employers and workers.4 These
negotiations are an important means through which organizations and trade unions can improve
working conditions and labor relations.

1016
1017

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
4

International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

Page 31 of 68

1018
1019

agreements can cover specific groups of workers, for example, those performing a specific activity or
working at a specific location.

1020
1021
1022
1023

This disclosure requires information about how the organization respects its employees’ rights tocollective bargaining and freedom of association. If the organization has a statement or policy
commitment on freedom of association and collective bargaining, this is to be reported under RBC-2b-i in this Standard and MT-3-a in GRI 103: Material Topics.

Commented [SD47]: Type of change: editorial
revision (change in location).

1024

See references 2, 3, 4, 5, 6, 9, 10, 21, 25, and 26 in the Bibliography section.

1025

Guidance to SE-2-aThis content was previously in the guidance to SE-2-aand had been moved to clarify the scope of thedisclosure.

1026
1027

SE-2-a requires the organization to report the percentage of its employees whose working conditions
and terms of employment are regulated by one or more collective bargaining agreements.

1028
1029
1030
1031
1032
1033
1034

This requirement does not ask for the percentage of employees belonging to trade unions, which canbe different. The percentage of employees covered by collective bargaining agreements can behigher than the percentage of unionized employees when an organization is required to apply thecollective bargaining agreements to both union and non-union members. Alternatively, the percentageof employees covered by collective bargaining agreements can be lower than the percentage ofunionized employees. This applies when there are no collective bargaining agreements available orwhen the collective bargaining agreements do not cover all unionized employees.

1035
1036

The percentage of employees covered by collective bargaining agreements is calculated using thefollowing formula:1037

Number of employees covered by collective bargaining agreements
× 100
Total number of employees reported under Disclosure ACT-2

1038
1039
1040
1041

The employees covered by collective bargaining agreements are those employees to whom theorganization is obliged to apply the agreement. This means that if none of the employees are 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.

1042
1043

Employees who are represented by a works council are not included under SE-2-a, unless the works
council engages in collective bargaining that results in a collective bargaining agreement.

1044
1045

The organization can also report the percentage of employees covered by collective bargaining
agreements per region or country, or provide comparisons with industry benchmarks.

1046

Guidance to SE-2-b

1047
1048
1049
1050
1051
1052
1053
1054

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. SE-2-b requires the organization to report if this is the case. If this is not the case, andthe working conditions and terms of employment of these employees is not influenced or determinedbased on other collective bargaining agreements, a brief statement of this fact is sufficient to comply
with this requirement.

1055
1056

If all of the organization’s employees are covered by collective bargaining agreements, a brief
statement of this fact is sufficient to comply with the requirement.

Page 32 of 68

Commented [SD48]: Type of change: revision
following public comment feedback.
New guidance added.

Commented [SD49]: Type of change: editorial
revision.
New guidance added.

Commented [SD50]: Type of change: revision
following public comment feedback.
New guidance added.

1057

Bibliography

1058
1059

This section lists authoritative intergovernmental instruments and other sources used in developing
this Standard, as well as additional resources that can be consulted by organizations.

1060

Authoritative instruments:

1061
1062

1. International Committee of the Red Cross (ICRC), the Geneva Conventions of 1949 and theirAdditional Protocols, 1949.

1063

2. International Labour Organization (ILO), Collective Agreements Recommendation, 1951 (No. 91).

1064

3. International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

1065

4. International Labour Organization (ILO), Collective Bargaining Recommendation, 1981 (No. 163).

1066
1067

5. International Labour Organization (ILO), Declaration on Fundamental Principles and Rights at
Work, 1998.

1068
1069

6. International Labour Organization (ILO), Freedom of Association and Protection of the Right toOrganise Convention, 1948 (No. 87).

1070
1071

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

1072
1073

8. International Labour Organization (ILO), Resolution concerning the International Classification of
Status in Employment (ICSE), 1993.

1074
1075

9. International Labour Organization (ILO), Right to Organise and Collective Bargaining Convention,
1949 (No. 98).

1076

10. International Labour Organization (ILO), Workers’ Representatives Convention, 1971 (No. 135).

1077
1078

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

1079
1080

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

1081
1082

13. Organisation for Economic Co-operation and Development (OECD), OECD Principles ofCorporate Governance, 2004.

1083
1084

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

1085

15. United Nations (UN), International Bill of Human Rights:

Commented [SD51]: Type of change: editorial
revision.

1086

15.1 United Nations (UN), Universal Declaration of Human Rights, 1948.

1087

15.2 United Nations (UN), International Covenant on Civil and Political Rights, 1966.

1088
1089

15.3 United Nations (UN), International Covenant on Economic, Social, and Cultural Rights,
1966.

1090
1091

15.4 United Nations (UN), Optional Protocol to the International Covenant on Civil andPolitical Rights, 1966.

1092
1093

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.

1094
1095

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

1096
1097
1098

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.

1099

18. United Nations (UN), Rio Declaration on Environment and Development, 1992.

Page 33 of 68

The “References” section has been renamed“Bibliography”. References are now grouped into three
types:• Authoritative instruments• Other sources – documents used when developing
the Standard other than authoritative instruments• Further resources – additional sources fororganizations to consult.
Commented [SD52]: Type of change: editorial
revision.
New authoritative instrument added.

Commented [SD53]: Type of change: editorial
revision.
New authoritative instrument added.

1100
1101

19. United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012.

1102

Other sources:

1103
1104

20. Committee on Workers’ Capital (CWC), Guidelines for the Evaluation of Workers’ Human Rights
and Labour Standards, 2017.

1105
1106
1107

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 23 February 2021.

1108
1109

22. International Labour Organization (ILO), ILOSTAT, https://ilostat.ilo.org/, accessed on 23
February 2021.

1110
1111
1112

23. International Labour Organization (ILO), Key Indicators of the Labour Market (KILM),
http://www.ilo.org/global/statistics-and-databases/research-and-databases/kilm/lang-en/index.htm, accessed on 23 February 2021.

1113
1114

24. International Labour Organization (ILO), Non-standard employment around the world:
Understanding challenges, shaping prospects, 2016.

1115
1116
1117
1118

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 23 February 2021.

1119

26. ShareAction, The Workforce Disclosure Initiative 2020 Survey Guidance Document, 2020.

1120

Further resources:

1121
1122
1123

27. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
Human Rights, and United Nations Global Compact, Human Rights Translated 2.0: A Business
Reference Guide, 2017.

1124
1125

28. Corporate Human Rights Benchmark Ltd., Corporate Human Rights Benchmark methodology,
updated annually.

1126

29. Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015.

1127
1128

30. Shift, Oxfam, and Global Compact Network Netherlands, Doing Business with Respect for Human
Rights: A Guidance Tool for Companies, 2016.

1129
1130

31. United Nations (UN), Methodology. Standard country or area codes for statistical use (M49),
http://unstats.un.org/unsd/methods/m49/m49regin.htm, accessed on 23 February 2021.

Page 34 of 68

1131

Annex. Revisions with track changes

1132

Section 2. Organization al details and1133

its reporting practices

1134
1135

The disclosures in this section provide an overview of the organization, its sustainability reporting
practices, and the entities that it includes in itsfor which it provides sustainability informationreporting.

1136

Disclosure REP-1 Organizational details

1137

Requirements

1138

The organization shall:1139

a. report its legal name;1140

b. report its nature of ownership and legal form;

1141

c. report theits location of its headquarters;

1142

d. report the its countries where it has significant of operations.

1143

Guidance

1144

Guidance to REP-1-a

1145
1146

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.

1147

Guidance to REP-1-b

1148
1149
1150

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 charitable organization.

1151

Guidance to REP-1-c

1152
1153

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

1154

Guidance to REP-1-d

1155
1156
1157
1158
1159
1160

The organization can also report specific locations within countries where it has significant operations,e.g., regions, states, or cities, where if this provides contextual information about the scale of its
activity and about thecontribution to to understand the organization’s impacts included in its
sustainability reporting. 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, theorganization can provide a link or reference to this information.

1161
1162

Disclosure REP-2 Organization’s Organizational eentities included
in its the sustainability reporting
Requirements

Page 35 of 68

1163

The organization shall:

1164

a. list its entities that are included in its sustainability reporting;

1165
1166
1167

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;

1168
1169

c. if the organization consists of multiple entities that form a consolidated group, explain theapproach used for consolidating the information, including:

1170
1171

i.

whether the approach involves adjustments to information for minority interests inthe case of entities that are not wholly owned;

1172
1173

ii.

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

1174

iii.

whether and, if so, how the approach differs across material topics.

Guidance
1175

Guidance to REP-2-a

1176
1177
1178
1179
1180

The entities reported under REP-2-a form the basis for reporting the remaining disclosures in thisStandard and for identifying the organization’s material topics and related impacts. The organization
should align the entities included in its sustainability reporting with the entities included in its otherstatutory and regulatory reporting, in particular, its financial reporting. See Section 5.1 of GRI 101:
Using the GRI Standards for more information.

1181
1182
1183

When identifying its material topics and related impacts, the organization should consider the impactsof additional entities with which it has business relationships, that are not included in the list reported
under REP-2-a. See Section 2 of GRI 103: Material Topics for more information.

1184

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

1185
1186
1187
1188

If all the entities in the organization’s financial reporting are also included in its sustainability reporting,the organization can provide a reference or link to the list of these entities included in its audited
consolidated financial statements or financial information filed on public record. Any additional entities
included in the sustainability reporting can then be separately identified.

1189
1190
1191

The organization can provide a reference or link to the list of entities included in its audited
consolidated financial statements or financial information filed on public record and specify which are
not included in its sustainability reporting.

1192
1193
1194

If all entities are included in its sustainability reporting, a brief statement of this fact and a reference orlink to the list of entities included in its audited consolidated financial statements or financial
information filed on public record is sufficient to meet the requirements in REP-2-a and REP-2-b.

1195
1196

The organization can separately report any additional entities included in the sustainability reportingthat are not included in the organization’s financial reporting

1197

Guidance to REP-2-c

1198
1199
1200

A consolidated group is a groupThe consolidated information covers of entities consisting of a theparent entity and the entities it controls and has an interest in its subordinate entities, such as
subsidiaries, joint ventures, and affiliates.

1201
1202

A minority interest is the an ownership or interest of in an subordinate entity , by a party otherthanthat is not controlled by the parent entity, in the consolidated group.

1203

Disclosure REP-3 Reporting period and frequency

1204

Requirements

Page 36 of 68

1205

The organization shall:1206

a. specify the reporting period for its sustainability reporting;

1207
1208
1209
1210

b. if the organization has audited consolidated financial statements or financial information
filed on public record, specify the reporting period for its financial reporting, and andprovide an explanation if it does not align with the period for its sustainability reporting,
explain the reason for this;1211

c. report the frequencypublication date and frequency of its sustainability reporting;1212

c.d. report the contact point for questions regarding the reported information..

1213

Guidance

1214

Guidance to REP-3-a and REP-3-b
The reporting period refers to the time period covered by the reported information (e.g., the year
ending 31 December 2021 or 1 July 2021 through 30 June 2022). The organization can specify thestart and end dates of the reporting period in the introduction of its report.

1215
1216
1217

The organization should align the reporting period for its sustainability reporting with the reporting
period for its other statutory and regulatory reporting, in particular, its financial reporting. See Section
5.1 of GRI 101: Using the GRI Standards. for more information.

1218

Guidance to REP-3-c

1219

The frequency of reporting refers to how often the organization carries out reporting, (e.g., annually).

1220

Disclosure REP-4 Restatements of information

1221

Requirements

1222

The organization shall:

1223
1224
1225

a. provide and explainreport any restatements of information made from previous reporting
periods and their effect, and explain report the reasons for such restatements and theireffect.

1226

Guidance1227

Background

1228
1229

This disclosure provides transparency on the reasons for restatements and their effects on thereported information.

1230

Guidance to REP-4-a

1231
1232
1233

If the organization restates information reported during previous reporting periods and includes therestated information in its reporting for the current period, it is required to explain the revision or
correction made under the restatement.

1234
1235
1236
1237
1238
1239
1240
1241

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 be provided to correct an error, or account for a changes in measurement methodology ora change in the business context. Providing Rrestatements of information enablesprovide consistency
and enable comparability of information between reporting periods, and helps information users to ininterpreting the reported information. See the reporting principle of Comparability in Section 4 of GRI
101: Using the GRI Standards for more information. This disclosure provides transparency on thereasons for such restatements and their effects on the reported information.

1242

Examples of rReasons for restatements of information can include:

Page 37 of 68

1243

•

errors made in previous reporting periods;

1244

•

disposals, mergers, or acquisitions;

1245

•

a change of base periods or reporting periods;

1246

•

change in the nature of the business;

1247

•

change in measurement methods.;

1248

•

disposals, mergers, or acquisitions;•errors made in previous reporting periods.;

1249
1250
1251

The organization can report the criteria it uses to determine when a change or an error in previously
reported information is considered significant enough to issue a restatement.

1252
1253
1254

The effect of the restatement refers to the actual revision or correction made to previously reported
information. If the restatement relates to quantitative information, the organization should specify thequantitative change in the restated information.

1255
1256
1257
1258
1259
1260
1261
1262
1263
1264

For example, suppose if an organization adopts a new, more accurate method for measuringgreenhouse gas (GHG) emissions, that is more accurate. As a result, it may subsequently
experiences a significant reduction in its reported GHG emissions that meets the organization’s
restatement criteria.due to the adoption of a new method for measuring emissions that is moreaccurate. The organization then restates its previously reported information on GHG emissions in its
reported information for the current period. In this case, the organization is required to explain that it
has restated its previously reported GHG emission levels due to the new measurement methodology,
and that this has resulted in lower GHG emissions than previously reported for these periods. The
organization should also report the quantitative change observed (e.g., GHG emissions are 10%
lower compared to the level of emissions previously reported).

1265

Disclosure REP-5 External assurance

1266

Requirements

1267

The organization shall:

1268
1269

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

1270

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

1271
1272

i.

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

1273
1274
1275

ii.

describe what has and what has not been assured and on what basis, including,the assurance standards used, the level of assurance obtained, and the limitationsof the assurance process;

1276

iii.

describe the relationship between the organization and the assurance provider.

1277

Guidance

1278

Guidance to REP-5-b-ii

1279
1280
1281
1282

The description of what has and what has not been assured, the assurance standards used, the levelof assurance obtained, and the limitations of the assurance process is sometimes included in theassurance report(s), ()conclusions, or opinions. If this is the case, the organization can provide a linkto this information included in the external assurance report(s), conclusions, or opinions.

1283
1284

If this is not the case, the organization is required to report a summary, in accessible language,reflecting the key elements covered in the external assurance report, including:Page 38 of 68

1285
1286

If the assurance reports or statements include a description of what has been assured, and on what
basis, then a link to this information is sufficient to meet the requirement.

1287
1288
1289

If the assurance reports or statements do not include a description of what has been assured, and on
what basis, then the organization is required to report a summary of the key elements covered in theexternal assurance report. The summary should be written in accessible language and include:

1290

•

the scope of information and processes covered;

1291

•

the and processes

1292

•

assurance and reporting standards used;

1293

•

the responsibilities of the organization relative to the assurance provider;

1294

•

the level of assurance obtained;

1295

•

any limitations of the assurance process;

1296

•

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

1297

•

a summary of the work performed; and•information on the experience and qualifications of the assurance providers.

1298
1299

See Section 5.2 of GRI 101: Using the GRI Standards for more information on external assurance.

1300

Guidance to REP-5-b-iii

1301
1302
1303
1304

An assurance provider conducting external assurance needs to demonstrate independence from theorganization in order to reach and publish objective and impartial conclusions about the organization’ssustainability reporting. See Section 5.2 of GRI 101: Using the GRI Standards for more information on
working with assurance providers.

Page 39 of 681305

Section 3. Organizational Aactivities

1306

and workers

1307
1308
1309

The disclosures in this section provide an overview of the organization’s activities and of its
employees and other workers. This contextual information helps information users better understandthe nature of the organization and its impacts on the economy, environment, and people.

1310
1311

Disclosure ACT-1 Activities, value chain, and other business
relationships

1312

Requirements

1313

The organization shall:

1314

a. report its sector;

1315

b. describe its value chain, including:

1316

i.

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

1317
1318

ii.

characteristics of the entities upstream from the organization and their activities
related to the organization’s products and services, i.e., its supply chain;

1319
1320

iii.

characteristics of the entities downstream from the organization and their activities
related to the organization’s products and services;1321

c. report other relevant business relationships;

1322
1323

d. describe significant changes in ACT-1-a, ACT-1-b, and ACT-1-c since compared to theprevious reporting period.

1324

Guidance

1325

Guidance to ACT-1-a

1326
1327
1328
1329

Sectors can be identified according to different groupingscategories, such as the public or private
sector, or industry-specific categories such as the education sector, or the financial sector. If theorganization is part of more than one sector, it can report those sectors that provide contextual
information to understand its impacts on the economy, environment, and people.

1330
1331
1332
1333
1334

Depending on the organization’s activities, sectors can be identified using various classification
systems that define categories for economic activities. For example, the UN-based International
Standard Industrial Classification of All Economic Activities [Ref no.], or investment-basedclassification systems such as the Global Industry Classification Standard or the Industry
Classification Benchmark [Ref no.].

1335
1336

The organization is required to use the GRI Sector Standard(s) that apply to its sector(s), where these
are available for its sector(s).

1337

Guidance to ACT-1-b

1338
1339
1340
1341
1342
1343
1344

The organization’s value chain includes the organization’s own activities, as well as activities carriedout by entities upstream and downstream from the organization in relatedion to the organization’s
products and services. Entities upstream from the organization are those that supply products orservices that are used in the development of contribute to the organization’s own products orservices. Entities downstream from the organization receive products or services from theorganization. Entities in the value chain include entities beyond the first tier, both upstream anddownstream.

Page 40 of 68

1345
1346
1347
1348
1349

The information required in ACT-1-b provides contextual information to understand the organization’s
impacts across its value chain, including through the use of its products and servicesThe information
required in ACT-1-b helps to understand the impacts that occur across the organization’s value chain,including through the 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.

1350

Guidance to ACT-1-b-i

1351
1352
1353
1354
1355
1356
1357
1358
1359
1360
1361

ACT-1-b-I does not require a detailed description of each activity of the organization. Instead, theWhen describing its main activities, tThe organization can provide a high-level overview of all its
activities. T The organization should report itsthe total number of operations (explain
more about what comprises activities here that we want reporting on) and . The organization should
also reportexplain how it defines the definition used for ‘operation’. For example, whether ‘operation’refers to a single location used by the organization for the production, storage, and/or distribution of
its products and services or for administrative purposes. When describing its main activities, theorganization should report the total number of operations. The organization should also report thedefinition used for ‘operation’. For example, whether ‘operation’ refers to a single location used by theorganization for the production, storage, and/or distribution of its productsgoods and services or foradministrative purposes.

1362

When describing its products and services, the organization should:

1363

•

report the quantity of products or services provided during the reporting period;

1364
1365
1366

•

describe report if any of its products or services are banned in certain markets it sells
products and services that are banned in certain markets or are the subject of stakeholder
concerns or public debate, and how the organization has responded to these concerns.

1367

When describing the markets served, the organization can:

1368
1369

•

report the markets it serves using geographic, demographic, or behavioral othercharacteristics of the markets;

1370
1371

•

reportspecify information on the size and relative importance of the markets served, forexample, by reporting net sales or net revenues.

1372

Guidance to ACT-1-b-ii

1373
1374
1375

When describing the characteristics of the entities upstream from the organization and the activities
they carry out in relation to the organization’s products and services (i.e., the supply chain), tTheorganization can describe:

1376

•

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

1377
1378

•

report the estimated number of suppliers throughout its supply chain (i.e., in the first tier,second tier, etc.);

1379
1380

•

report the types of activities of its suppliers (e.g., manufacturing of the organization’s
products, providingsion of services);

1381
1382
1383

•

specify the nature of itsthe business relationship it has with its suppliers (e.g., long-term or
short-term, contractual or non-contractual. contract, project-based or event-based
relationship);

1384

•

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

1385

•

report the estimated monetary value of payments made to its suppliers;

1386

•

specify the geographic locations of its suppliers.

1387

Guidance to ACT-1-b-iii

1388
1389
1390

When describing the characteristics of the entities downstream from the organization and theactivities they carry out in relation to the organization’s products and services, tThe organization can
describe:

1391
1392

•

specify the types of customers and beneficiaries (e.g., end consumers, other businesses,
recipients of the products or services from a social enterprise or a nonprofit organization);

Page 41 of 68

1393

•

report the estimated number of downstream entities (i.e., in the first tier, second tier, etc.);

1394
1395

•

report the types of activities of these downstream entities (e.g., wholesalers, manufacturers,
retailers);

1396
1397

•

specify the nature of the its business relationship it has with theits downstream entities (e.g.,long-term or short-term contract, project-based or event-based relationship);•specify the geographic locations of the downstream entities.

1398
1399

Guidance to ACT-1-c

1400
1401
1402
1403

Other relevant business relationships include relationships that the organization has with entities thatare not described as part of the organization’sits value chain under ACT-1-b. These can consist of
business partners (e.g., joint ventures) and other entities directly linked to the organization’s
operations, products, or services.

1404
1405
1406

When describing other relevant business relationships, the organization can specify report the typesof entities, their activities they perform related to the organization’s products and services, and theirgeographic location.

1407

Guidance to ACT-1-d

1408
1409
1410
1411
1412
1413
1414
1415

ThACT-1-d requires the organization to describe significant changes in e description of significant
changes to the its organization’s sector, value chain, and other business relationships helps
understand any variations in the reported information since compared to the previous reporting
period. This information can help explain variations in the organization’s impacts included in its
sustainability reporting. Examples of significant changes that can be reported under this disclosure
include are changes in activities, such as the opening, closing, or expansion of, facilitiesy openings,
closings, and expansions;, changes in the structure of the the organization’s supply chain or in its
relationships with suppliers;, orand changes in the locations of its suppliers.

1416

Disclosure ACT-2 Employees and other workers

1417

Requirements

1418

The organization shall:

1419
1420

a. report the total number of employees, and and provide aitsa breakdown of this total ofthis total by gender and by region;:1421

c.b. report the total number of:

1422
1423

i.

employment contract (permanent employees , with aand its breakdown by genderand by region;

1424

ii.

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

1425
1426

v.iii.

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

1427
1428

vi.

employment contract (permanent employees and temporary employees), byregion;

1429
1430

iv.

employment type (full-time employees, and itswith a breakdown by gender and byregion;1431
1432

vii.v.

, part-time employees, and ), itswith a breakdown by gender and by regionby
gender;;

1433

viii.

employment type (full-time employees, part-time employees employees), by region;

Page 42 of 68

1434
1435

d.c. provide contextual information to understand the data reported under ACT-2-a and ACT-2b;

1436
1437

e. report the total number of workers who are not employees and whose work is controlled
by the organization, including:

1438
1439

ix.

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

1440

x.

the work they perform;

1441
1442

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

1443
1444

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

1445

xi.vi.

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

1446
1447

xii.vii.

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

1448

Guidance1449

Background

1450
1451
1452
1453

This disclosure provides requires information about on the number of employees and other workers
who are not employees that perform work for the organization. To understand how many workers intotal perform work for the organization, it is important to know the number of workers who are not
employees as these are not represented in formal employment figures.

1454
1455
1456
1457
1458
1459

Thise disclosure, together with Disclosure ACT-3 on workers who are not employees, gives insight
into the organization’s approach to employment, as well as the scope and nature of impacts createdby labor issues arising from employment practices. It also provides contextual information to thathelps understand the information reported in other disclosures, and it serves as the basis forcalculation in several disclosures, such as the disclosure on the percentage of employees covered bycollective bargaining agreements.

1460
1461
1462

This disclosure covers all employees and all workers who are not employees who perform work forany of the organization’s entities included in its sustainability reporting (reported under Disclosure
REP-2).

1463

See references 6, 7, 8, 16, 22, 25, and 27 in the References Bibliography section.

1464

Guidance to ACT-2-a

1465
1466

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

1467
1468
1469
1470

Providing a breakdown of employees by gender gives insight into gender representation and diversity
across an organization. Providing a breakdown of employees by region gives insight into regional
representation and variations. Region can refer to a country or to other geographical areas like cities
and world regions.

1471

See Tables 1-2 for examples of how to present this information.

1472

Guidance to ACT-2-b

1473
1474
1475
1476
1477
1478

The definitions of permanent, temporary and non-guaranteed hours, o identify the full-time, and parttime, employees employment contract and employment type differ between countries. For example,
the national legislations vary in their definitions of a full-time contract. If the organization has
employees in more than one country, it of its employees, the organization should use the definitions
under as per the national laws of the countries where the employees are based to first calculate
country-level data. The country-level data , as what constitutes an employment contract andPage 43 of 68

1479
1480
1481
1482

employment type varies between countries. For example, the national legislations vary in theirdefinitions of a full-time contract. If the organization has employees in more than one country, it
should be added up the country-level data to calculate the total numbers, disregarding differences innational legal definitions.

1483
1484
1485
1486
1487

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

1488
1489
1490

Providing a breakdown of the data on employees by employment contract and employment type by
gender enables an understanding of gender representation and diversity across an organization. The
organization can report information for gender categories in addition to male and female.

1491
1492
1493

Providing a breakdown of the data on employees by employment contract and employment type by
region enables an understanding of regional representation and variations across regions. Region canrefer to a ‘country ’ or a ‘geographical area’.

1494
1495
1496

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 1000, to the nearest
100.

1497

See Tables 1-24 for examples ofn how to present this datainformation.

1498

Guidance to ACT-2-cb

1499
1500
1501
1502
1503
1504

Quantitative data, such as the number of temporary orand part-time employees is unlikely to provide
sufficient information on its own. For example, a high number proportion of temporary or part-time
employees could indicate a lack of employment security for employees, but it could equally signal
workplace flexibility when offered as a voluntary choice. For this reason, quantitative data should beaccompanied by contextual information to help information users formulate an appropriate
interpretation ofunderstand the data and formulate an appropriate interpretation.

1505
1506
1507
1508
1509

The organization can explain the reasons for temporary employment. An eExample of such a reason
could be the recruitment of employees (e.g., to undertake work on a temporary or seasonal projects
or events. , or because itAnother example could be that it is standard practice to offer a temporary(e.g., 6 month) contract to new employees prior to the offer of permanent employment. The
organization can also explain the reasons for non-guaranteed hours employment.

1510
1511

If differences in employment contracts exist between genders or between regions, the organization
can explain the reasons for these differences.

1512
1513
1514
1515
1516
1517
1518

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 forin the different
regionsThe organization can also explain how full-time employment is defined and whether the samedefinition applies globally. SimilarlyFurther, the organization can explain the reasons for part-time
employment. Examples of such reasons could be (e.g., to accommodate employees’ requests to work
reduced hours, or because the organizationit is unable to provide full-time employment to all
employees).

1519
1520
1521
1522

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). up.The organization can also explain how full-time employment is defined and whether
the same definition applies globally.

1523
1524
1525

If differences in employment types exist there are differences in full-time, part-time, or non-guaranteed
hours employment between genders or between regions, the organization can explain the reasons forthese differences.providing a breakdown of the data on employeesthe different

1526

Guidance to ACT-2-c

1527
1528
1529
1530

Workers who are not employees are those who perform work for the organization but are not in an
employment relationship with the organization (e.g., agency workers, contractors, self-employedpersons, volunteers). ACT-2-c provides an understanding of how much the organization relies on
workers who are not employees to perform its work compared to employees.

Page 44 of 68

1531
1532
1533
1534

Control of work implies that the organization directs the work performed or has control over the meansor methods for performing the work. The organization might have sole control of the work or sharecontrol with one or more organizations (e.g., suppliers, customers, or other business partners, suchas in joint ventures).

1535
1536
1537

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 1000, to the nearest 100.

1538
1539
1540

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 meet therequirement.

1541

Guidance to ACT-2-c-i and ACT-2-c-ii

1542
1543
1544
1545
1546
1547
1548

ACT-2-c-i requires the organization to report the most common types of worker who are not
employees. The organization can use the following categories to report the types of worker: agency
workers, apprentices, contractors, home workers, interns, self-employed persons, sub-contractors,
volunteers. The organization is also required to report its contractual relationship with the mostcommon types of worker, i.e., whether it engages them directly or indirectly through a third party, andin the latter case, who this third party is (e.g., employment agency, sub-contractor). ACT-2-c-ii
requires the organization to describe the work performed by the most common types of worker.

1549
1550

It is sufficient to provide a general description; the organization is not required to report the type ofworker, contractual relationship, and work performed for every worker that is not an employee.

1551

Guidance to ACT-2-d

1552
1553
1554

It is up to the organization to determine which fluctuations in the number of employees it considers
significant to report under this disclosure. The organization should report its threshold for identifying
significant fluctuations.

1555
1556
1557
1558
1559
1560
1561

The organization is required to describe all fluctuations in the number of employees and workers who
are not employees that it deems significant. The description can include how the numbers vary (e.g.,i.e., whether the numbers have increased or decreased during the reporting period or in comparison
to the previous reporting period). It can also include, and the reasons for the fluctuations. F, forexample, (e.g., an increase in workers who are notthe number of employees during the reporting
period could be due to a seasonal event. taking place, or A a decrease in the number of employees incomparison to the previous reporting period could be due to the completion of a temporary project).

1562
1563
1564

If there are no significant fluctuations in the number of employees and workers who are not
employees during the reporting period or between reporting periods, a brief statement of this fact issufficient to meet thecomply with the requirement.

1565

Guidance to ACT-2-ee

1566
1567
1568
1569

The organization should report the total number of employees and the number of employees by
employment type (full-time and part-time employees) in head count. The head count gives insight into
the number of individual workers employees performing work for the organization, whether on a fulltime or part-time basis.

1570
1571
1572

The organization can report the number of employees by employment contract (permanent, andtemporary, and non-guaranteed hours employees) in head count or full-time equivalent (FTE).
Reporting these numbers in FTE gives insight into the hours worked.

1573

The organization can also use another methodology for reporting these numbers if that is appropriate.

1574
1575
1576
1577
1578

Reporting the number of employees and workers who are not employees at the end of the reporting
period provides information for that point in time, without capturing any fluctuations during thereporting period. Reporting these numbers in averages across the reporting period takes into accountfluctuations during the reporting period.

Page 45 of 68

1579

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

Female[Number]

Page 46 of 68

Male[Number]

Other gendercategory*[Number]Not disclosed[Number]

1580
1581
1582
1583

Number of part-time employees [head count]
Total[Number]

Female[Number]Male[Number]

Other gendercategory*[Number]Not disclosed[Number]

1584
1585
1586
1587
1588
1589
1590
1591

1592

* as specified by the employees

1593

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

Region A[Number]

Page 47 of 68

Region B[Number]Number of part-time employees [head count]
Total[Number]

Region A[Number]

Region B[Number]

1594

Disclosure ACT-3 Workers who are not employees

1595

Requirements

1596

The organization shall:

1597

h. report the total number of employees, and provide a breakdown of this total by:

1598

xiii.

employment contract (permanent and temporary), by gender;

1599

xiv.

employment contract (permanent and temporary), by region;

1600

xv.

employment type (full-time and part-time), by gender;

1601

xvi.

employment type (full-time and part-time), by region;1602

i. provide contextual information to understand the data reported under ACT-2-a;

1603
1604

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

1605
1606

xvii.viii.

1607

ix.

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

1608
1609

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

1610
1611

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

1612

i.

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

1613
1614

ii.

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

1615

Guidance1616

Background

1617
1618
1619
1620
1621
1622
1623
1624

This disclosure provides requires information about on the number of employees and other workers
who are not employees that and whoand whose perform work for theis controlled by the organization.
The information is important in order Tto understand how many workers in total perform work for theorganization, it is important to know the number of workers who are not employees, in addition to thenumber of employees reported under ACT-2, abecauses theseworkers who are not employees are
not represented in formal employment figures reported under Disclosure ACT-2. ACT-2-c This
disclosure provides an understanding of how much the organization relies on workers who are not
employees to perform its work compared to employees.

Page 48 of 68

1625
1626
1627
1628
1629
1630

Thise disclosure, together with Disclosure ACT-2 on employees, gives insight into the organization’s
approach to employment, as well as the scope and nature of impacts created by labor issues arisingfrom its employment practices. It also provides contextual information that helpsto understand theinformation reported in other disclosures, and serves as the basis for calculation in several
disclosures, such as the the disclosure on the percentage of employees covered by collective
bargaining agreements:.

1631
1632
1633

This disclosure covers all employees and all workers who are not employees and who perform work
for any of the organization’s entities included in its sustainability reporting (reported under Disclosure
REP-2).

1634

See references 8, 20, 226, 237, 24 8, 26,16, 22, 25, and 3127 in the References Bibliography section.

1635

Guidance to ACT-3-a2-c

1636
1637
1638
1639

Workers who are not employees are those who perform work for the organization but are not in an
employment relationship with the organization (e.g., agency workers, contractors, self-employedpersons, volunteers). ACT-2-c provides an understanding of how much the organization relies on
workers who are not employees to perform its work compared to employees.

1640
1641

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

1642
1643
1644

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.

1645
1646
1647
1648
1649
1650

The organization mayight have sole control of the work or share control with one or moreorganizations (e.g., suppliers, customers, or other business partners, such as in joint ventures).
Workers who are not employees and whose work is controlled by the organization can work for theorganization or for the organization’s suppliers, customers, or other business partners, such as joint
ventures. Types of such workers can be agency workers, apprentices, contractors, home workers,
interns, self-employed persons, sub-contractors, or volunteers.

1651
1652

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

1653
1654
1655
1656
1657
1658
1659
1660
1661
1662
1663
1664
1665
1666

•
•
•

Contractors hired by the organization to perform work at the organization’s workplace, in a
public area (e.g., on a road, on the street), or directly at the workplace of the organization’sclient;Workers of the organization’s supplier, where the organization instructs the supplier to use
particular materials or work methods in manufacturing the products or delivering the services.
Volunteers or interns performing work for the reporting organization.

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

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;
Workers of a supplier contracted by the organization who work using the supplier’s work
methods, such as when the organization sources products from a supplier, and these arestandard products of the supplier.

1667
1668
1669

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 1000, to the nearest 100.

1670
1671
1672

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 meetthecomply with requirement.

1673

Guidance to ACT-3--a2-c-i and ACT-32-ac-ii

1674
1675

ACT-32-ac-i requires the organization to report the most common types of worker who are not
employees,. The organization can use the following categories to report the types of worker: agency

Page 49 of 68

1676
1677
1678
1679

workers, apprentices, contractors, home workers, interns, self-employed persons, sub-contractors,
volunteers. The organization is also required to report its contractual relationship with the mostcommon types of worker, i.e., whether it engages them directly or it engages them indirectly through athird party, and in the latter case, who this third party is (e.g., employment agency, sub-contractor).

1680
1681

ACT-32-ac-ii requires the organization to describe the work performed by the most common types ofworker.

1682
1683
1684

It is sufficient if the organization provides a general description. It is sufficient to provide a generaldescription; tThe organization is not required to report the type of worker, contractual relationship, andwork performed for every worker that who is not an employee.

1685

Guidance to ACT-32-bd

1686
1687
1688

It is up to the The organization to determine which is required to describe all fluctuations in thenumber of employees and workers it considers significant to report under this disclosure. The
organization should report its threshold for identifying significant fluctuations.

1689
1690
1691
1692
1693
1694
1695

who are not employees that it deems significant. The description can include how the numbers vary,i.e., (e.g., whether the numbers have increased or decreased during the reporting period or incomparison to the previous reporting period. It can also include), and the reasons for the fluctuations.
F, for example, (e.g., an increase in workers who are not employees during the reporting period could
be due to a seasonal event taking place. A, or a decrease in the number of employees workers who
are not employees in comparison to the previous reporting period could be due to the completion of atemporary project).

1696
1697
1698

If there are no significant fluctuations in the number of employees and workers who are not
employees during the reporting period or between reporting periods, a brief statement of this fact issufficient to meet thecomply with the requirement.

1699

Guidance to ACT-32-ce

1700
1701
1702
1703

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 also
use another methodology for reporting these numbers if that is appropriate.

1704
1705
1706
1707

Reporting the number of employees and workers who are not employees at the end of the reporting
period provides information for that point in time, without capturing any fluctuations during thereporting period. Reporting these numbers in averages across the reporting period takes into accountfluctuations during the reporting period.

1708

Section 5. Responsible business

1709

conductStrategy, policies, and1710

practices

1711
1712
1713

The disclosures in this section provide an overview of thean organization’s sustainable development
strategy and its policies and practices for responsible business conduct. The disclosures are basedon expectations for businesses contained in internationally recognized authoritative intergovernmental

Page 50 of 68

1714
1715
1716
1717
1718
1719

instruments5, which include the International Labour Organization (ILO), Tripartite Declaration of
Principles concerning Multinational Enterprises and Social Policy; the Organisation for Economic Cooperation and Development (OECD), OECD Guidelines for Multinational Enterprises and OECD Due
Diligence Guidance for Responsible Business Conduct; and the United Nations (UN), Guiding
Principles on Business and Human Rights. These instruments in turn are based on international legal
instruments, such as the UN’s International Bill of Human Rights and the ILO conventions.

1720
1721
1722
1723
1724
1725

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 regard combating bribery, bribe
solicitation, extortion, and other forms of corruption; and adhering to good tax practices; as well as. In
addition, they include conducting due diligence in order to identify, prevent, mitigate, and account for
how an organization addresses its negative impacts on the economy, environment, and people.

1726
1727
1728
1729
1730
1731

The disclosures in this section require information about the organization’s policies and practices forresponsible business conduct generally rather than for its material topics specifically. Disclosure MT-3
in GRI 103: Material Topics requires information about how the organization manages each material
topic. If the organization has described its policies and practices for a material topic under thedisclosures in this section, it can provide a reference to this information under MT-3 and does notneed to repeat the information.

1732
1733

Disclosure SPPRBC-1 Statement on sustainable development
strategy

1734

Requirements

1735

The organization shall:

1736
1737
1738

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

1739

Guidance

1740

Guidance to SPPRBC-1

1741

The organization shoulds describetatement should include:

1742
1743
1744
1745

•

the its short, medium and long-term vision and strategy for the short-term, medium-term, andlong-term, with respect to managingto manage the organization’s impacts on the economy,
environment, and people, including impacts on human rights, across its activities andbusiness relationships – including impacts on human rights;

1746
1747
1748
1749

•

how the organization'sits purpose, business strategy and business model are designed orchanged in orderaim to avoid negative impacts and achieve positive impacts on the economy,
environment, and peoplechanges in the business model to address impacts to sustainable
development;

1750
1751
1752

•

its short-term and medium-term strategic priorities for contributing to sustainable
development, including the relation to and observance of internationally recognized standards
and agreements;

5

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

Page 51 of 68

1753
1754

•

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

1755
1756

•

the key events, achievements, and failures with respect toregarding the organization’scontributions to sustainable development during the reporting period;

1757
1758

•

a view of performance against goals and targets for the organization’s material topics forcontributin that gcontributed to sustainable development during the reporting period;

1759
1760
1761

•

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

1762
1763
1764
1765

When determining whether the highest governance body or most senior executive provides reports
the required statement, the organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which couldan be related
to:

1766

•

the country where the organization is incorporated or registered;

1767

•

a stock exchange where the organization trades its securities on;

1768
1769

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

1770

Disclosure RBCSPP-2 Policy commitments

1771

Requirements

1772

The organization shall:

1773

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

1774
1775

i.

the internationally recognizedauthoritative intergovernmental instruments that thecommitments reference;

1776

ii.

whether the commitments stipulate conducting due diligence;

1777

iii.

whether the commitments stipulate applying the precautionary principle;

1778

iv.

whether the commitments stipulate respecting human rights;

1779

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

1780

i.

the internationally recognized human rights that the commitment covers;

1781
1782

ii.

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

1783
1784

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

1785
1786

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

1787
1788
1789
1790

e. report whether the extent to which the policy commitments apply solely to theorganization’s own activities or whether they also stipulate the organization’s
expectations of those with which it hasand to its business relationships and, if so,
describe what those expectations are;

1791
1792

f.

1793
1794

g. if the organization does not have any of the policy commitments in RBC-2-a, explain thereason for not having them or describe any plans to develop them.

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

Page 52 of 68

1795

Guidance

1796

Background

1797
1798
1799
1800

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.

1801
1802
1803
1804

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

1805

Guidance to RBCSPP-2-a

1806
1807

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

1808
1809

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

1810

Guidance to RBCSPP-2-a-i

1811
1812
1813

The introduction to thisSee the Bibliography section (i.e., Section 5for a list of this Standard) provides
examples of internationally recognizedauthoritative intergovernmental instruments for responsible
business conduct.

1814

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

1815

Guidance to RBCSPP-2-a-iii

1816
1817
1818
1819

The precautionary principle is set out in Principle 15 of the UN Rio Declaration on Environment andDevelopment. 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.’

1820
1821
1822
1823
1824

Applying 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 is sufficient reason to expect serious or irreversible damage, in advance of complete scientificunderstanding or evidence, to prevent and mitigate potential negative impacts on people’s health andthe environment.

1825
1826
1827

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.

1828
1829
1830

The application of the precautionary principle can be reported under MT-3-d-i in GRI 103: Material
Topics, as part of the organization’s actions to prevent or mitigate potential negative impacts for eachmaterial topic.

1831

Guidance to RBCSPP-2-b-i

1832
1833
1834

Human rights are rights inherent to all human beings, regardless of nationality, place of residence,
sex, national or ethnic origin, color, religion, language, or any other status. These rights are allinterrelated, interdependent, and indivisible.

1835
1836
1837

The internationally recognized human rights include, at a minimum, the rights set out in the UN
International Bill of Human Rights and the principles concerning fundamental rights set out in the ILO
Declaration on Fundamental Principles and Rights at Work.

1838
1839

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 and theirPage 53 of 68

1840
1841

families. There are also standards of international humanitarian law that apply in situations of armed
conflict, such as the International Committee of the Red Cross (ICRC) Geneva Conventions of 1949.6

1842
1843

At the regional level, binding treaties as well as non-binding instruments provide region-specificframeworks for human rights.7

1844
1845
1846
1847
1848
1849

If the policy commitment covers all internationally recognized human rights, a brief statement of thisfact is sufficient to meet the requirement. The organization can also state if the policy commitment
references certain rights that require particular attention. For example, it 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.

1850
1851
1852

If the policy commitment only covers only some internationally recognized human rights, theorganization is required to state the rights that are covered. In addition, it can explain why the policy
commitment is limited to these rights.

1853

Guidance to RBCSPP-2-b-ii

1854
1855
1856
1857
1858
1859
1860
1861
1862

Categories of stakeholders that the organization gives particular attention to can include consumers,
customers, employees, local communities, and workers, among others.. They can also include
individuals belonging to groups or populations that are considered to be at risk or vulnerable or at risk,such as womenchildren; human rights defenders; indigenous peoples; 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); indigenous peoples; national or ethnic, religious
and linguistic minorities; children; persons with disabilities; migrant workers and their families; and/or
human rights defenders; persons with disabilities; or women.

1863
1864
1865

For example, a bank might give particular attention in its policy commitment to avoid discriminating
against specific categories of customers, or a mining company might give particular attention to avoid
infringing on the rights of indigenous peoples.

1866

Guidance to RBCSPP-2-d

1867
1868
1869

The most senior level canmay differ between organizations. For example, the most senior level inanthe organization cancould be the highest governance body (e.g., the board), or it cancould be themost senior executive (e.g., chief executive officer).

1870
1871

The organization can also report the dates of approval and adoption of the policy commitments (ifdifferent from the date of their approval), and how frequently theythe commitments are reviewed.

1872

Guidance to RBCSPP-2-e

1873
1874

If the policy commitments apply to all of the organization’s own activities and business relationships
equally, a brief statement of this fact is sufficient to meet the requirement.

1875
1876
1877
1878

If the policy commitments apply to only some of the organization’s own activities (e.g., they apply only
to entities located in certain countries, or to certain subsidiaries), the organization can should reportwhich of its activities the commitments apply to and it can additionally explain why the commitments
are limited to these activities.

1879
1880
1881
1882

If the policy commitments stipulate expectations forapply to only some of the organization’s business
relationships, the organization can should specify the types of business relationships thecommitments apply to (e.g., distributors, franchisees, joint ventures, suppliers), and it can additionallyexplain why the expectationscommitments are limited to these business relationships.

6 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 6
May 2020.
7 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 6 May 2020.

Page 54 of 68

1883
1884
1885

When describing the organization’s expectations of those with which it has business relationships,
The organization canshould also explain whether theythe business relationships are obligated toabide by the policy commitments or are encouraged (but not obligated) to do so.

1886

Guidance to RBCSPP-2-f

1887

The organization can report:

1888
1889

•

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;

1890
1891

•

the means through which it communicates the policy commitments (e.g., newsletters, formal
or informal meetings, dedicated websites, contractual agreements);

1892
1893

•

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).

1895

Disclosure RBCSPP-3 Embedding the policy commitments
throughout the organization

1896

Requirements

1897

The organization shall:

1898
1899

a. describe how the organization embeds each of its policy commitments for responsible
business conduct throughout its activities and business relationships, including:

1894

1900
1901

i.

how the organization it allocates responsibility for to implementing thecommitments across different levels within the organization;

1902
1903

ii.

how the organizationit integrates the commitments into organizational strategies,
and operational policies, and operational procedures;

1904
1905

iii.

how the organization works with those with which it hasit implements its
commitments in its business relationships, to implement the commitments;

1906

iv.

training that the organization provides on implementing the commitments.

1907

Guidance

1908

Background

1909
1910
1911
1912

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 in order to ensure. This ensures that people at all levels act responsibly andwith awareness of and respect for human rights.

1913

Guidance to RBCSPP-3-a-i

1914
1915

TheExamples of different levels within an organization can include the highest governance body,senior executives, and operational levels.

1916

The organization can report:

1917
1918

•

the most senior level with oversight of, or accountability for, the implementation of the policy
commitments;

1919
1920
1921

•

the functions in the organization with day-to-day responsibility for implementing each of thepolicy commitments (e.g., human resources with the responsibility for to implementing thecommitment to respect the rights of workers), including:

1922

-

their reporting lines to senior decision-making levels, and ;

1923

-

the reason for allocating the responsibility to them;

Page 55 of 68

1924
1925

•

whether responsible business conduct is formally discussed at meetings of the highest
governance body or senior executives and, if so, which topics are discussed;

1926
1927
1928

•

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).

1929

Guidance to RBCSPP-3-a-ii

1930

The organization can describe:

1931

•

how it aligns the policy commitments with its:

1932

-

broader risk management systems and management policies;

1933
1934

-

environmental, socioeconomic, and socialhuman rights impact or risk assessments, andother due diligence processes;

1935
1936

-

policies and procedures that set financial and other performance incentives for
management or workers;

1937
1938

•

how it applies the policy commitments when making decisions, such as about its sourcing andoperating locations;

1939
1940
1941

•

the systems (e.g., internal audit) it uses for to monitoring compliance with the policy
commitments acrossthroughout its activities (across functions and geographic locations) andthroughout its business relationships.

1942

Guidance to RBCSPP-3-a-iii

1943

The organization can describe:

1944
1945

•

its procurement or investment policies and practices, and its engagement with those withwhich it has business relationships, including:

1946
1947
1948

-

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;

1949
1950

-

whether and how it considers the policy commitments in contracting or investment
agreements, or in specific policies or codes of conduct for suppliers;

1951
1952

-

whether and how it considers the policy commitments in the process of determining
whether to initiate, continue, or terminate a business relationship;

1953
1954

•

processes through which it enables or supports business partners and other parties toimplement the policy commitments (e.g., capacity building, peer sharing);

1955
1956

•

incentives that it offers to business partners and other parties to implement the policy
commitments (e.g., price premiums, increased orders, or long-term contracts).

1957

Guidance to RBCSPP-3-a-iv

1958

The organization can report:

1959

•

the content of the training;

1960

•

to whom the training is provided, and whether it is mandatory;

1961

•

the form (e.g., in-person, online) and frequency of the training;

1962

•

examples of how the organization has determined that the training is effective.

1963
1964
1965
1966

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, or ensuring the policy commitments are considered in procurement
practices).

1967
1968

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, as well

Page 56 of 68

1969
1970
1971
1972

as. The organization can also specify if training is provided to those with which the organizationit has
business relationships (e.g., distributors, franchisees, joint ventures, suppliers). In addition, theorganization can also report the number or percentage of individualsworkers, business partners, andother parties that have been trained during the reporting period.

1973
1974

Disclosure RBCSPP-4 Grievance mechanisms and otherremediation processes

1975

Requirements

1976

The organization shall:

1977
1978

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;

1979

b. describe its approach to identify and address grievances, including:

1980

i.

the grievance mechanisms that the organization has established or participates in;

1981
1982

ii.

other processes by which the organization provides for or cooperates in theremediation of negative impacts that it identifies it has caused or contributed to;

1983
1984
1985

c. describe how the stakeholders who are the intended users of the grievance mechanisms
and other remediation processes are involved in the design, review, operation, andimprovement of these mechanisms and processes;

1986
1987
1988

d. describe how the organization tracks the effectiveness of the grievance mechanisms andother remediation processes, and providereport examples of their effectiveness, including
stakeholder feedback.

1989

Guidance

1990

Background

1991
1992
1993
1994
1995

This disclosure covers grievance mechanisms and other remediation processes that the organization
has established or participates in. These mechanisms and processes enable stakeholders to raise
concerns about impacts (, and seek remedy for, the organization’s actual and potential) that theorganization has negative impacts on them, including. This includes impacts on their human rights,
and to seek remedy. .

1996
1997
1998
1999
2000
2001
2002
2003

The UN Guiding Principles on Business and Human Rights and the OECD Guidelines forMultinational Enterprises set out expectations for organizations to provide for or cooperate in theremediation, through legitimate processes, of negative impacts that they identify they have caused orcontributed to, and to establish or participate in effective operational-level grievance mechanisms. An
organization is not responsible for providing remediation for negative impacts that are directly linked
to its operations, products, or services by its business relationships, but it can play a role in providing
it. See Box 3 in GRI 103: Material Topics for more information on causing, contributing, or being
directly linked to negative impacts.

2004
2005

These instruments also set out expectations for organizations to establish or participate in effective
operational-level grievance mechanisms.

2006
2007
2008
2009

Grievance mechanisms are distinct from whistleblowering mechanisms. Whistleblowering
mechanisms enable individuals to raise concerns about wrongdoing or breaches of the law in theorganization’s operations or business relationships, regardless of whether the individuals themselves
are harmed or not. Whistleblowering mechanisms are to be reported under Disclosure RBCSPP-5.

2010

Guidance to RBCSPP-4

2011
2012
2013

This disclosure covers the operation of grievance mechanisms and other remediation processes thatthe organization has established or participates in to enable stakeholders to raise concerns about theorganization’s actual and potential negative impacts on them. The actions taken to provide for or

Page 57 of 68

2014
2015

cooperate in the remediation of actual negative impacts for material topics are to be reported underMT-3-d-ii in GRI 103: Material Topics.

2016
2017
2018
2019
2020
2021

The disclosure does not cover environmental remediation processes, such as processes to remove
contaminants from soil, when these are not connected to grievances raised by stakeholders.
However, the remedy provided to stakeholders through the mechanisms and processes covered bythis disclosure cancould involve environmental remediation. The use of environmental remediation
processes to address actual negative impacts for material topics can be reported under MT-3-d-ii in
GRI 103: Material Topics.

2022
2023
2024

Examples where the organization has provided for or cooperated in the remediation of specificnegative impacts through grievance mechanisms and other remediation processes, as well as
environmental remediation processes, are to be reported under MT-3-b-ii in GRI 103: Material Topics.

2025

Guidance to RBCSPP-4-b-i

2026
2027

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.

2028
2029
2030
2031
2032

Examples of state-based grievance mechanisms, both judicial and non-judicial, grievancemechanisms 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 governmentrun complaints offices.

2033
2034
2035
2036
2037

Non-state-based grievance mechanisms include those administered by the organization, either alone
or together with stakeholders, such as operational-level grievance mechanisms. It also includes
collective bargaining and the mechanisms established by collective bargaining, as well asmechanisms administered by industry associations, international organizations, civil society
organizations, or multi-stakeholder groups.

2038
2039
2040
2041
2042

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, and can. They also provide important feedback on the effectivenessof the organization’s due diligence from those who are directly affected.

2043

The organization can describe:

2044
2045
2046
2047
2048
2049

•

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 anda separate hotline for workers to raise concerns about issues affecting their rights, such as
health and safety conditions;

2050
2051

•

how the mechanisms operate and who administers them (the organization and/or anotherparty);

2052
2053
2054
2055

•

forwhether operational-level grievance mechanisms, are administered at the organizational
level or whether they are administered at the organizational level or at a lower level, such as(at the site or project level,) and, in the lattersuch case, how datainformation from thesemechanisms is centralized;

2056
2057
2058

•

how the mechanisms have been designed and theon which principles and guidelines on
which they are based, including whether they are designed to meet the effectiveness criteria
set out in UN Guiding Principle 31;

2059

•

the process through which grievances are investigated;

2060

•

whether grievances are communicated to the highest governance body;

2061

•

whether grievances are treated confidentially;

2062
2063

•

whether the mechanisms can be used by stakeholders anonymously through representation
by a third party;

Page 58 of 68

2064
2065

•

whether the organization requires or provides incentives for the creation or improvement ofoperational-level grievance mechanisms in workplaces of suppliers;

2066
2067
2068

•

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.

2069

Guidance to RBCSPP-4-b-ii

2070

RBCSPP-4-b-ii covers remediation processes other than grievance mechanisms.

2071
2072
2073
2074

Examples include a customer service desk where customers can raise complaints about
discrimination or privacy issues and receive remedy, or instances where the organization takes action
to remediate an actual impact evidenced in an impact assessment or a report published by a civilsociety organization.

2075
2076

See Guidance to RBCSPP-4-b-i for more information on how to report ondescribe other remediation
processes.

2077

Guidance to RBCSPP-4-c

2078
2079
2080

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.

2081

Guidance to RBCSPP-4-d

2082
2083
2084
2085
2086
2087

According to UN Guiding Principle 31, 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 is acknowledged that It can be more difficult for the organization to assess theeffectiveness of grievance mechanisms that it participates in compared to those it has establisheditself.

2088

The organization can report:

2089
2090

•

whether and how the intended users are informed about the grievance mechanisms andremediation processes and trained on how to use them;

2091
2092

•

whether and how the intended users are trained on how to use the grievance mechanisms
and remediation processes;

2093
2094
2095

•

the accessibility of the grievance mechanisms and remediation processes, such as the total
number of hours per day or days per week that they are available, and their availability indifferent languages;

2096
2097
2098

•

how the organization seeks to ensure that users are treated with respect and protectedit
respects users’ human rights and protects them against reprisals (i.e., non-retaliation for
raising complaints or concerns);

2099
2100

•

how satisfied users are with the grievance mechanisms and remediation processes or, andwith the resulting outcomes, andas well as how the organization assesses users’ satisfaction;

2101
2102
2103

•

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;

2104

•

the number of grievances filed during the reporting period that are repeated or recurring;

2105
2106

•

changes made to the grievance mechanisms and remediation processes in response tolessons learned about their effectiveness.

2107
2108
2109
2110
2111

Quantitative information, 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
equallyalso signal that the mechanisms are not trusted by their intended users. For this reason,contextual information should be provided to aid in understanding and interpreting the quantitative
information.

Page 59 of 68

2113

Disclosure SPPRBC-5 Mechanisms for seeking advice and raisingconcerns

2114

Requirements

2115

The organization shall:

2116

a. describe the mechanisms for individuals to:

2112

2117
2118

i.

seek advice on implementing the organization’s policies and practices forresponsible business conduct;

2119

ii.

raise concerns about the organization’s responsible business conduct.

2120

Guidance

2121

Background

2122
2123
2124
2125
2126

This disclosure covers the an 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.

2127
2128
2129
2130
2131
2132
2133

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 actual and potential
negative impacts (actual and potential) that the organization has on them, . This including includes
impacts on their human rights., and to seek remedy. Grievance mechanisms are to be reported under
Disclosure SPPRBC-4.

2134

Guidance to SPPRBC-5

2135
2136
2137
2138

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 clearly stateexplain which mechanisms thedescription covers.

2139

Guidance to SPPRBC-5-a

2140

The organization can report:

2141

•

who the intended users of the mechanisms are;

2142
2143

•

how the mechanisms operate and which level or function in the organization is assigned
responsibility for them;

2144
2145

•

whether the mechanisms are operated independently of the organization (e.g., by a third
party);

2146•

the process through which concerns are investigated;

2147

•

whether requests for advice and concerns raised are treated confidentially;•

whether the mechanisms can be used anonymously.

2148
2149

Additionally, the organization can report on the effectiveness of the mechanisms, including:

2150
2151

•

whether and how the intended users are informed aboutof the mechanisms and trained on
how to use them;

2152
2153

•

the accessibility of the mechanisms, such as the total number of hours per day or days per
week that they are available, and their availability in different languages;

Page 60 of 68

2154
2155

•

how the organization seeks to ensure it respects users’ human rights are treated with respect
and protects them ed against reprisals (i.e., non-retaliation for reporting concerns);

2156

•

how satisfied users are with the mechanisms or and with the resulting outcomes;

2157
2158

•

the number and types of requests for advice received during the reporting period, and thepercentage of requests that were answered;

2159
2160

•

the number and types of concerns raised during the reporting period, and the percentage ofconcerns that were addressed and resolved, orresolved or found to be unsubstantiated.

2161

Disclosure RBCSPP-6 Compliance with laws and regulations

2162

Requirements

2163

The organization shall:

2164
2165
2166

a. report the total number of significant instances of non-compliance with laws or regulations forwhich significant fines or non-monetary sanctions were incurred during the reporting period, with abreakdown of this total byincluding:

2167

iii.

total monetary value of the significant fines incurred;

2168
2169

i.

instances for which total number of significant fines were incurred and their monetary
value;

2170

i.ii.

instances for which and total number of non-monetary sanctions were incurred;

2171
2172

ii.

the nature of each instance of non-compliance for which a significant fine or nonmonetary sanction was incurred;

2173

b. describe the significant instances of non-compliance;

2174

c. describe how it has determined significant instances of non-compliance.

2175
2176
2177

b.d.report instances of non-compliance with laws or regulations raised through dispute resolution
mechanisms during the reporting period, including the nature of each instance of noncompliance.

2178

Guidance2179

Background

2180
2181
2182
2183

Non-compliance is failure to comply with the laws and/or regulations. This disclosure addresses noncompliance, or failure to comply with, all laws and regulations related to economic, environmental,
and social matters that are applicable to the organization.. Non-compliance is the failure to comply
with thesuch laws and/or regulations.

2184
2185

These laws and regulations can be issued by a variety of bodies including governments (local,
regional, and national), regulatory authorities, and public agencies.

2186

Laws and regulations include:

2187

•

international declarations, conventions, and treaties;

2188

•

national, subnational, regional, and local regulations;

2189
2190

•

binding voluntary agreements made with regulatory authorities and developed as a substitutefor implementing a new regulation;

Page 61 of 68

2191
2192
2193

•

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.

2194
2195
2196

Laws and regulations relating to economic and social matters include topics such as accounting andtax fraud, corruption, bribery, corruption, competition, the provision of products and services, or labor
issues, such as workplace discrimination.

2197
2198

Laws and regulations relating to environmental matters include topics such as biodiversity, emissions,energy, material use, spills and leaks, waste, and water and effluents.

2199
2200
2201
2202
2203

Non-compliance with laws and regulations can give insight into the ability of management to ensurethat the organization conforms to certain performance parameters. In some circumstances, noncompliance can lead to remediation obligations or liabilities other than fines, such as clean-up
obligations in the case of environmental issues. The strength of an organization’s compliance record
can also influence its ability to gain permits and consequently to expand operations.

2204

Guidance to RBC-6

2205

Guidance to SPP-6-a

2206
2207

The scope of this disclosure includes instances of non-compliance that resulted in administrative or
judicial sanctions induring the reporting period.

2208
2209
2210

Non-monetary sanctions include restrictions imposed by governments, regulatory authorities, or publicagencies, on the organization’s activities or operations, such as withdrawal of trading licenses or
licenses to operate in highly regulated industries.

2211
2212

AnThe organization can include fines that have been reported in its audited consolidated financial
statements or in the financial information filed on public record.

2213
2214

If the organization has not incurred any fines or non-monetary sanctions for non-compliance with laws
or regulations, a brief statement of this fact is sufficient to meet the requirement.

2215
2216
2217

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.

2218

Guidance to SPP-6-b

2219
2220
2221
2222

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, i.e., economic, environmental, or
social matters applicable to the organization. The organization should report sufficient information forstakeholders to understand the type and context of the significant instances of non-compliance.

2223

The organization can explain whether the significant instances are repeated or recurring.

2224

Guidance to SPP-6-c

2225
2226
2227
2228
2229

A fine or non-monetary sanction is significant if it could influence decision-making by information
users making use of the organization’s reported information. If the fine or non-monetary sanction isreported in the organization’s audited consolidated financial statements or in the financial information
filed on public record, it can be considered significant and is required to be reported under thisdisclosure.

2230
2231

If the organization has not incurred any significant fines or non-monetary sanctions for noncompliance with laws or regulations, a brief statement of this fact is sufficient to meet the requirement.

2232
2233

When describing how the organization has determined significant instances of non-compliance, it can
include:Page 62 of 68

2234

•

the severity of the impact thatresulting from the instance resulted in;

2235

•

external benchmarks used in its sector to determine significant instances of non-compliance.

2236

Disclosure SPPRBC-7 Membership associations

2237

Requirements

2238

The organization shall:

2239
2240

a. report industry associations, and other membership associations, and national and orinternational advocacy organizations in which it participates in has a significant role.

2241

Guidance

2242

Guidance to SPPRBC-7

2243
2244
2245
2246
2247

The organization could 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. It could also apply when the organization , orviews its membership as strategic to influencing the mission or objective of the association that is
critical to the organization’s own activities.

2248

Section 6. Stakeholder engagement

2249
2250

This section includes disclosures on the organization’s stakeholder engagement practices, including
how it engages in collective bargaining with employees.

2251

Disclosure SE-1 Approach to stakeholder engagement

2252

Requirements

2253

The organization shall:

2254

a. describe its approach to engaging with stakeholders, including:

2255

i.

the categories of stakeholders it engages with, and how they are identified;

2256

ii.

the purpose of the stakeholder engagement;

2257

iii.

how the organization seeks to ensure meaningful engagement with stakeholders.

2258

Guidance

2259

Guidance to SE-1

2260
2261
2262

Stakeholders are individuals or groups whothat have interests that are, affected or could be, affectedby the organization’s activities and decisions.. For more information on stakeholders, see Section 2.4
ofin GRI 101: Using the GRI Standards.

2263
2264

This disclosure covers stakeholder engagement undertaken by the organization as part of its ongoing
activities rather than specifically for the purpose of sustainability reporting.

2265

Guidance to SE-1-a-i

Page 63 of 68

2266
2267
2268
2269

Common categories of stakeholders for organizations includeare 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.

2270
2271

The organization can explain how it determines which categories of stakeholders to engage with andwhich categories not to engage with.

2272

Guidance to SE-1-a-ii

2273
2274
2275
2276
2277

The organizationpurpose of stakeholder engagement can report the types of activities and decisions
for which it engages with stakeholdersbe, for example, to identify actual and potential negative
impacts, or to determine prevention and mitigation responses to potential negative impacts. In somecases, stakeholder engagement is a right in and of itself, for example,such as the right of workers toform or join trade unions or their right to bargain collectively.

2278

The organization can additionallyalso report:

2279
2280
2281
2282

•

the type and frequency (e.g., annually, quarterly) of stakeholder engagement. For example,
whether the engagements are (e.g., participation, consultation, information) and its frequency(e.g., ongoing (e.g., in the case of systemic issues) or whether they are specific engagementswith particular groups or for particular operations or projects, quarterly, annually);

2283
2284
2285

•

when the organizationit engages directly with stakeholders and when it engages with credible
stakeholder representatives or proxy organizations, or other credible independent expert
resources, and why;

2286
2287
2288

•

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 datainformation fromstakeholder engagement activities is centralized;•

the resources (e.g., financial or human resources) allocated to stakeholder engagement.

2289
2290
2291
2292
2293
2294

Further information on stakeholder engagement undertaken for specific activities, for example, for the
setupsuch as setting up and operation ofoperating grievance mechanisms and other remediation
processes, or for the identificationdetermining and management ofmanaging material topics andrelated impacts, is reported under other disclosures (RBCSPP-4-d in this Standard, and MT-1-a-iii
and MT-3-df in GRI 103: Material Topics).

2295

Guidance to SE-1-a-iii

2296
2297
2298
2299
2300

As stated inMeaningful stakeholder engagement is, according to the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Business Conduct,
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.

2301

The organization can report:

2302
2303

•

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);

2304
2305

•

how it engages with at-risk or vulnerable groups, such as (e.g., whether it takes specificapproaches and gives special attention to potential barriers);

2306
2307

•

how it provides stakeholders with information that is understandable and accessible throughappropriate communication channels;

2308
2309
2310

•

how stakeholder feedback is recorded and integrated into decision-making, and how
stakeholders are informed about howthe way in which their feedback has influenced
decisions;

2311
2312

•

how it seeks to respect the human rights of all stakeholders engaged, such as their rights to
privacy, freedom of expression, and peaceful assembly and protest;

Page 64 of 68

•

2313
2314
2315

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.

2316

Disclosure SE-2 Collective bargaining agreements

2317

Requirements

2318

The organization shall:

2319

a. report the percentage of total employees covered by collective bargaining agreements;

2320
2321
2322
2323

b. for employees not covered by collective bargaining agreements, report whether it
determines their working conditions and terms of employment based on its existingcollective bargaining agreements that coverwith its other employees or based oncollective bargaining agreements from other organizations.

2324

Guidance2325

Background

2326
2327

The right to collective bargaining is a fundamental right at work that is covered in the ILO Right toOrganise and Collective Bargaining Convention [Ref no. 9].

2328
2329
2330
2331
2332
2333

Collective bargaining refers to negotiations that take place between one or more employers or
employers' organizations and one or more workers' organizations (trade unions). The objective of
these negotiations is to reach a collective agreement on working conditions and terms of employment(e.g., wages and working time) andor to regulate relations between employers and workers.8 These
negotiations are an important means through which organizations and trade unions can improve
working conditions and labor relations.

2334
2335
2336
2337

Collective agreements can be made at the level of the organization, at the level of a particular site,
and/or at the industry level, andand/ or at the national level in countries where this is the practice.
Collective agreements can cover specific groups of workers, for example, those performing a specificactivity or working at a specific location.

2338
2339
2340
2341

This disclosure requires information about how the organization respects its employees’ rights tocollective bargaining and freedom of association. If the organization has a statement or policy
commitment on freedom of association and collective bargaining, this is to be reported under RBC-2b-i in this Sstandard and MT-3-a in GRI 103: Material Topics.)

2342

See references 1, 2, 3, 4, 5, 6, 9, 10, 214, 256, and 267 in the References Bibliography section.

2343

Guidance to SE-2-a

2344
2345
2346
2347
2348

SE-2-a provides enablesrequires the organization to report information on the proportion percentageof the organization’sits employees whose working conditions and terms of employment (e.g., wages
and working time) are regulated by one or more collective bargaining agreements. This can giveinsight into whether the organization respects its employees’ rights to collective bargaining andfreedom of association.

2349
2350
2351
2352
2353
2354
2355
2356

This requirement does not ask for the percentage of employees belonging to trade unions, whichmight can be a different number. The percentage of employees covered by collective bargaining
agreements can be higher than the percentage of unionized employees when an organization isrequired to apply the collective bargaining agreements to both union and non-union members.
Alternatively, the percentage of employees covered by collective bargaining agreements can be lower
than the percentage of unionized employees. This applies when there are no collective bargaining
agreements available or when the collective bargaining agreements do not cover all unionizedemployees.

8International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

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2357
2358

The percentage of total employees covered by collective bargaining agreements is calculated using
the following formula:2359

Number of employees covered by collective bargaining agreements
× 100
Total number of employees reported under Disclosure ACT-2

2360
2361
2362
2363

The employees covered by collective bargaining agreements are those employees to whom theorganization is obliged to apply the agreement. This means that if none of the employees are coveredby a collective bargaining agreement, the percentage reported is zero. AnIf an employee is coveredby more than one collective bargaining agreement, it only needs to be counted once.

2364
2365

Employees who are represented by a works council are not included under SE-2-a, unless the works
council engages in collective bargaining that results in a collective bargaining agreement.

2366
2367

If none of the organization’s employees are covered by collective bargaining agreements, a brief
statement of this fact is sufficient to meet thecomply with the requirement.

2368
2369

The organization can additionally also report the percentage of employees covered by collective
bargaining agreements per region or country, or provide comparisons with industry benchmarks.

2370

Guidance to SE-2-b

2371
2372
2373
2374
2375

SE-2-b only applies to organizations where some or all employees are not covered by collective
bargaining agreements. In these cases, the organization might determine the working conditions andterms of employment of these employees based on its existing collective bargaining agreements thatcover other employees (as reported under SE-2-a) or based on collective bargaining agreements fromother organizations. SE-2-b requires the organization to report if this is the case.

2376
2377

If all the organization’s employees are covered by collective bargaining agreements, the organization
does not need to report the information in SE-2-b.

2378
2379
2380
2381
2382
2383
2384
2385

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. SE-2-b requires the organization to report if this is the case. If this is not the case, andthe working conditions and terms of employment of these employees is not influenced or determinedbased on other collective bargaining agreements, a brief statement of this fact is sufficient to comply
with this requirement.

2386
2387

If all of the organization’s employees are covered by collective bargaining agreements, a brief
statement of this fact is sufficient to comply with the requirement.

2388

ReferencesBibliography

2389
2390
2391
2392

The following documents informed the development of this Standard and can be helpful forunderstanding and applying it. This section lists authoritative intergovernmental instruments and othersources used in developing this Standard, as well as additional resources that can be consulted byorganizations.

2393

Authoritative intergovernmental instruments:

2394
2395

1. International Committee of the Red Cross (ICRC), the Geneva Conventions of 1949 and theirAdditional Protocols, 1949.

2396
2397

1.2. International Labour Organization (ILO), Collective Agreements Recommendation, 1951 (No.
91).

2398

2.3. International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

2399

3.4. International Labour Organization (ILO), Collective Bargaining Recommendation, 1981 (No. 163).

2400
2401

4.5. International Labour Organization (ILO), Declaration on Fundamental Principles and Rights at
Work, 1998.

Page 66 of 68

2402
2403

5.6. International Labour Organization (ILO), Freedom of Association and Protection of the Right toOrganise Convention, 1948 (No. 87).

2404
2405

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

2406
2407

6. International Labour Organization (ILO), ILOSTAT, https://ilostat.ilo.org/, accessed on 6 May
2020.

2408
2409
2410

7. International Labour Organization (ILO), Key Indicators of the Labour Market (KILM),
http://www.ilo.org/global/statistics-and-databases/research-and-databases/kilm/lang-en/index.htm, accessed on 6 May 2020.

2411
2412

8. International Labour Organization (ILO), Resolution concerning the International Classification of
Status in Employment (ICSE), 1993.

2413
2414

9. International Labour Organization (ILO), Right to Organise and Collective Bargaining Convention,
1949 (No. 98).

2415

10. International Labour Organization (ILO), Workers’ Representatives Convention, 1971 (No. 135).

2416
2417

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

2418
2419

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

2420
2421

13. Organisation for Economic Co-operation and Development (OECD), OECD Principles ofCorporate Governance, 2004.

2422
2423

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

2424

15. United Nations (UN), International Bill of Human Rights:

2425

15.1 United Nations (UN), Universal Declaration of Human Rights, 1948.

2426

15.2 United Nations (UN), International Covenant on Civil and Political Rights, 1966.

2427
2428

15.3 United Nations (UN), International Covenant on Economic, Social, and Cultural Rights,
1966.

2429
2430

15.4 United Nations (UN), Optional Protocol to the International Covenant on Civil andPolitical Rights, 1966.

2431
2432

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.

2433
2434

16. United Nations (UN), Methodology. Standard country or area codes for statistical use (M49),
http://unstats.un.org/unsd/methods/m49/m49regin.htm, accessed on 6 May 2020.

2435
2436

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

2437
2438
2439

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

2440

19.18. United Nations (UN), Rio Declaration on Environment and Development, 1992.

2441
2442

20.19. United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive
Guide, 2012.

2443

Other relevant referencessources:

2444
2445
2446

21. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
Human Rights, and United Nations Global Compact, Human Rights Translated 2.0: A Business
Reference Guide, 2017.

2447
2448

22.20. Committee on Workers’ Capital (CWC), Guidelines for the Evaluation of Workers’ Human
Rights and Labour Standards, 2017.

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2449
2450

23. Corporate Human Rights Benchmark Ltd., Corporate Human Rights Benchmark methodology,
updated annually.

2451
2452
2453

24.21. 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 6 May 202023 February 2021.

2454
2455

22. International Labour Organization (ILO), ILOSTAT, https://ilostat.ilo.org/, accessed on 6 May
202023 February 2021.

2456
2457
2458

23. International Labour Organization (ILO), Key Indicators of the Labour Market (KILM),
http://www.ilo.org/global/statistics-and-databases/research-and-databases/kilm/lang-en/index.htm, accessed on 6 May 202023 February 2021.

2459
2460

25.24. International Labour Organization (ILO), Non-standard employment around the world:
Understanding challenges, shaping prospects, 2016.

2461
2462
2463
2464

26.25. 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 6 May 202023 February 2021.

2465
2466

27.26. ShareAction, The Workforce Disclosure Initiative 2019 2020 Survey Guidance Document,
202019.

2467
2468

United Nations (UN), Methodology. Standard country or area codes for statistical use (M49),
http://unstats.un.org/unsd/methods/m49/m49regin.htm, accessed on 6 May 2020.

2469

Further resources:

2470
2471
2472

27. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
Human Rights, and United Nations Global Compact, Human Rights Translated 2.0: A Business
Reference Guide, 2017.

2473
2474

28. Corporate Human Rights Benchmark Ltd., Corporate Human Rights Benchmark methodology,
updated annually.

2475

28.29. Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015.

2476
2477

30. Shift, Oxfam, and Global Compact Network Netherlands, Doing Business with Respect for
Human Rights: A Guidance Tool for Companies, 2016.

2478
2479
2480

29.31. United Nations (UN), Methodology. Standard country or area codes for statistical use (M49),
http://unstats.un.org/unsd/methods/m49/m49regin.htm, accessed on 6 May 202023 February
2021.

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