[draft] GRI-ESRS Interoperability Index
About this [draft] index
Crediting the close cooperation during the development of the draft European Sustainability Reporting Standards (ESRS), EFRAG and
GRI have acknowledged that they have achieved a high level of interoperability between the ESRS and GRI Standards in relation to
impact reporting. This [draft] index is prepared from an EU standpoint where entities in scope of the CSRD will be subject to the
mandatory regime defined by the ESRS, including disclosures and definitions where requirements of topical standards are subject to amateriality assessment of matters and information. Therefore, this [draft] Interoperability Index is a mapping tool that helps entities
understand the commonalities between the two sustainability reporting standards in regard to impacts.
Given the high level of interoperability achieved, entities reporting under ESRS can be considered as reporting ‘with reference’ to the
GRI Standards (see GRI 1: Foundation 2021). The [draft] index shows the relationship between the ESRS and GRI disclosures tofacilitate reporting ‘with reference’ to the GRI Standards.
When performing its materiality assessment, an ESRS reporter may conclude that some of the matters and disclosures that are notspecifically addressed by ESRS and are identified as a difference with the GRI Standards, might be reported in the ESRS sustainability
statement as entity-specific disclosures, when the conditions in ESRS 1 paragraph 11 are met.
The [draft] index may also support ESRS reporters that want to report ‘in accordance’ with the GRI Standards (see GRI 1: Foundation2021), in which case they would have to report the additional applicable GRI requirements not covered by the ESRS in theirsustainability statement, in accordance with the provisions of ESRS 1 paragraph 114.
To further simplify reporting processes, EFRAG and GRI are working on a digital correspondence table to achieve digitalinteroperability for the ESRS and GRI Standards. Shared disclosures tagged under the ESRS digital taxonomy and the GRI digitaltaxonomy could be cross-referenced to allow for a streamlined digital reporting exercise on the preparer’s side.

How to use the [draft] index
This [draft] Interoperability Index follows a columnar format mapping the GRI Standards disclosures to the corresponding ESRS
disclosure requirements at a granular level. The columns called ‘Notes’ and ‘Explanation’ describe the differences that arise at
datapoint level. These differences do not impair the overall objective of entities reporting under ESRS, that prepare their ESRS
sustainability statement, effectively claiming to report ‘with reference’ to the GRI Standards.
For ease of reading:• Where column D and E are blank, no differences are highlighted.
• Column D includes a categorisation system to clearly explain the nature of the identified differences. These differences, which may
affect only a single datapoint of a given disclosure requirement, have been classified in three groups: (1) differences in granularity ordata type; (2) differences in scope; and (3) differences in definition.
• In column C, there are several instances where GRI Standards disclosures are not covered by the list of sustainability matters in
ESRS 1 paragraph AR 16; in particular, in relation to the provisions of the CSRD (for instance, on certain governance matters such as
tax transparency). These instances are highlighted with light grey.

Additional resources

For more reporting support, please visit:www.globalreporting.org/standards
https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/corporate-sustainability-reporting-directiv© GRI & EFRAG 2023
[30 November 2023 Draft Version]

Disclaimer
The [draft] GRI-ESRS Interoperability Index aims to offer non-authoritative guidance on technical implementation questions related to European Sustainability
Reporting Standards (ESRS). EFRAG assumes no responsibility or liability whatsoever for the content or any consequences or damages direct, indirect or incidental
arising from following the advice or guidance contained in the answers. Users of this platform are advised to exercise their own judgment. Information, including
answers to the questions raised, contained in this platform should not be substituted for the services of an appropriately qualified professional.

EFRAG is funded by the European Union through the Single Market Programme in which the EEA-EFTA countries (Norway, Iceland and Liechtenstein), as well as
Kosovo participate. Any views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union, theEuropean Commission or of countries that participate in the Single Market Programme. Neither the European Union, the European Commission nor countries
participating in the Single market Programme can be held responsible for them.

GRI STANDARDSGRI 2: General
Disclosures 2021

GRI DISCLOSURES AND
REQUIREMENTS
2-1 Organizational details

ESRS DISCLOSUREREQUIREMENTS
See requirements of Directive
2013/34/EU

2-2 Entities included in theorganization’s sustainability reporting

ESRS 1 5.1; ESRS 2 BP-1 §5 (a)and (b) i

2-3 Reporting period, frequency andcontact point

ESRS 1 §73

NOTES

EXPLANATION(2-3-a and 2-3-b)

2-4 Restatements of information

ESRS 2 BP-2 §13, §14 (a) to (b)2-5 External assurance

See external assurance
requirements of Directive (EU)2022/2464
ESRS 2 SBM-1 §40 (a) i to (a) ii,(b) to (c), §42 (c)2-6 Activities, value chain and otherbusiness relationships
2-7 Employees

2-8 Workers who are not employees

ESRS 2 SBM-1 §40 (a) iii; ESRSS1 S1-6 §50 (a) to (b) and (d) to(e), §51 to §52
ESRS S1 S1-7 §55 to §56(3)

GRI 2-8 covers workers
who are not employees andwhose work is controlled by
the organization. ESRS S17 covers non-employee
workers: people with
contracts with theundertaking to supply
labour (“self-employedpeople”) or people provided
by undertakings primarily
engaged in “employment

activities” (NACE CodeN78).

2-9 Governance structure andcomposition(2-9-a [for public-interest entities only], 2-9b, 2-9-c-i, c-ii, c-v to c-viii)

2-10 Nomination and selection of thehighest governance body
2-11 Chair of the highest governancebody

ESRS 2 GOV-1 §21, §22 (a), §23;
ESRS G1 §5 (b)See also corporate governancestatement requirements of
Directive 2013/34/EU for publicinterest entities
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.

2-12 Role of the highest governancebody in overseeing the management of
impacts

This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
ESRS 2 GOV-1 §22 (c); GOV-2§26 (a) to (b); SBM-2 §45 (d);ESRS G1 §5 (a)2-13 Delegation of responsibility for
managing impacts

ESRS 2 GOV-1 §22 (c) i; GOV-2§26 (a); ESRS G1 G1-3 §18 (c)2-14 Role of the highest governancebody in sustainability reporting

ESRS 2 GOV-5 §36; IRO-1 §53(d)

2-15 Conflicts of interest

This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.

2-16 Communication of criticalconcerns

ESRS 2 GOV-2 §26 (a); ESRS G1
G1-1 AR 1 (a); G1-3 §18 (c)2-17 Collective knowledge of thehighest governance body

ESRS 2 GOV-1 §23

2-18 Evaluation of the performance ofthe highest governance body
2-19 Remuneration policies(2-19-a [for listed undertakings only] and 219-b)

2-20 Process to determine
remuneration[for listed undertakings only]

2-21 Annual total compensation ratio

This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
ESRS 2 GOV-3 §29 (a) to (c);ESRS E1 §13
See also remuneration reportrequirements of Directive (EU)2017/828 for listed undertakings
ESRS 2 GOV-3 §29 (e)See also remuneration reportrequirements of Directive (EU)2017/828 for listed undertakings
ESRS S1 S1-16 §97 (b) to (c)(2-21-a and 2-21-c)

2-22 Statement on sustainable
development strategy
2-23 Policy commitments(2-23-a-i and a-iv; 2-23-b, 2-23-d, 2-23-e,
2-23-f)

2-24 Embedding policy commitments

2-25 Processes to remediate negative
impacts

ESRS 2 SBM-1 §40 (g)ESRS 2 GOV-4; MDR-P §65 (b) to(c) and (f); ESRS S1 S1-1 §19 to§21, and §AR 14; ESRS S2 S2-1
§16 to §17, §19, and §AR 16;
ESRS S3 S3-1 §14, §16 to §17and §AR 11; ESRS S4 S4-1 §15
to §17, and §AR 13; ESRS G1
G1-1 §7 and §AR 1 (b)ESRS 2 GOV-2 §26 (b); MDR-P§65 (c); ESRS S1 S1-4 §AR 35;
ESRS S2 S2-4 §AR 30; ESRS S3
S3-4 §AR 27; ESRS S4 S4-4 §AR
27; ESRS G1 G1-1 §9 and §10 (g)ESRS S1 S1-1 §20 (c); S1-3 §32(a), (b) and (e), §AR 31; ESRS S2
S2-1 §17 (c); S2-3 §27 (a), (b) and(e), §AR 26; S2-4 §33 (c); ESRSS3 S3-1 §16 (c); S3-3 §27 (a), (b)and (e), §AR 23; S3-4 §33 (c);ESRS S4 S4-1 §16 (c); S4-3 §25(a), (b) and (e), §AR 23; S4-4 §32(c)2-26 Mechanisms for seeking advice
and raising concerns

2-27 Compliance with laws andregulations

2-28 Membership associations

2-29 Approach to stakeholder
engagement

2-30 Collective bargaining agreements

ESRS S1 S1-3 §AR 32 (d); ESRSS2 S2-3 §AR 27 (d); ESRS S3 S33 §AR 24 (d); ESRS S4 S4-3 §AR
24 (d); ESRS G1 G1-1 §10 (a);G1-3 §18 (a)ESRS 2 SMB-3 §48 (d); ESRS E2
E2-4 §AR 25 (b); ESRS S1 S1-17§103 (c) to (d) and §104 (b);ESRS G1 G1-4 §24 (a)'Political engagement' is asustainability matter for G1
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS 2 SMB-2 §45 (a) i to (a) iv;
ESRS S1 S1-1 §20 (b); S1-2 §25,
§27 (e) and §28; ESRS S2 S2-1
§17 (b); S2-2 §20, §22 (e) and§23; ESRS S3 S3-1 §16 (b); S3-2
§19, §21 (d) and §22; ESRS S4
S4-1 §16 (b); S4-2 §18, §20 (d)and §21
ESRS S1 S1-8 §60 (a) and §61

(1a)

(2b)

GRI 2-27 covers all
significant non-compliancewith laws and regulations,and breakdowns by typesof incidents of noncompliance. ESRS
requirements cover
information on current
financial effects, noncompliance with regards topollution, anti-corruption
and anti-bribery, andsevere human rights
incidents, in a number of
topical standards.

GRI 3: Material
Topics 2021

GRI 201: Economic
Performance 2016

3-1 Process to determine material
topics
3-2 List of material topics

ESRS 2 BP-1 §AR 1 (a); IRO-1§53 (b) ii to (b) iv
ESRS 2 SBM-3 §48 (a) and (g)3-3 Management of material topics

ESRS 2 SBM-1§ 40 (e); SBM-3§48 (c) i and (c) iv; MDR-P, MDRA, MDR-M, and MDR-T; ESRS S1
S1-2 §27; S1-4 §39 and AR 40(a); S1-5 §47 (b) to (c); ESRS S2
S2-2 §22; S2-4 §33, §AR 33 and§AR 36 (a); S2-5 §42 (b) to (c);ESRS S3 S3-2 §21; S3-4 §33,
§AR 31, §AR 34 (a); S3-5 §42 (b)to (c); ESRS S4 S4-2 §20, S4-4
§31, §AR 30, and §AR 33 (a); S45 §41 (b) to (c)201-1 Direct economic value generated
and distributed
201-2 Financial implications and otherrisks and opportunities due to climatechange201-3 Defined benefit plan obligations
and other retirement plans
201-4 Financial assistance received
from government

GRI 202: Market
Presence 2016

202-1 Ratios of standard entry level
wage by gender compared to local
minimum wage

See below for additional linkages
to specific topics.
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
ESRS 2 SBM-3 §48 (a), and (d) to(e); ESRS E1 §18; E1-3 §26; E1-9
§64
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
ESRS S1 S1-10 §67-71 and §AR
72 to 73(2b)

GRI 202-1 requires
information on the ratio of
the entry level wage by
gender at significant
locations of operation to theminimum wage. ESRS S110 requires information onwhether all its employeesare paid an adequate wage,
in line with European Union
regulation and applicablebenchmarks.
202-2 Proportion of senior
management hired from the local
community

GRI 203: Indirect
Economic Impacts
2016

203-1 Infrastructure investments andservices supported

203-2 Significant indirect economic
impacts
GRI 204:
Procurement
Practices 2016

3-3 Management of material topics
204-1 Proportion of spending on local
suppliers'Communities’ economic, socialand cultural rights' is asustainability matter for S3
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
'Communities’ economic, socialand cultural rights' is asustainability matter for S3
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS S1 S1-4 §AR 41; ESRS S2
S2-4 §AR 37; ESRS S3 S3-4 §AR
36
ESRS G1 G1-2 §12'Communities’ economic, socialand cultural rights' is asustainability matter for S3
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed

(2b)

(2b)

(2b)

according to ESRS 1 §11 andpursuant to MDR-M.

GRI 205: Anticorruption 2016

3-3 Management of material topics
205-1 Operations assessed for risks
related to corruption

GRI 206: Anticompetitive
Behavior 2016
GRI 207: Tax 2019205-2 Communication and training
about anti-corruption policies andprocedures
205-3 Confirmed incidents ofcorruption and actions taken
206-1 Legal actions for anti-competitive
behavior, anti-trust, and monopoly
practices207-1 Approach to tax

207-2 Tax governance, control, andrisk management
207-3 Stakeholder engagement andmanagement of concerns related to tax
207-4 Country-by-country reporting

GRI 301: Materials
2016

3-3 Management of material topics

ESRS G1 G1-1 §7; G1-3 §16 and§18 (a) and §24 (b)ESRS G1 G1-3 §AR 5

ESRS G1 G1-3 §20, §21 (b) and(c) and §AR 7 and 8
ESRS G1 G1-4 §25
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
This topic is not covered by the listof sustainability matters in ESRS 1
AR §16.
ESRS E5 E5-1 §12; E5-2 §17; E53 §21

(1b)

(1b)

GRI 205-1 requires
quantitative data on theextent of the risk
assessment. ESRS G1-3
§AR 5 is a narrative
disclosure.
See GRI 205-1.

GRI 302: Energy
2016301-1 Materials used by weight orvolumeESRS E5 E5-4 §31 (a)301-2 Recycled input materials used

ESRS E5 E5-4 §31 (c)301-3 Reclaimed products and theirpackaging materials'Resource outflows related to
products and services' and 'Waste'
are sustainability matters for E5
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS E1 E1-2 §25 (c) to (d); E1-3
§26; E1-4 §33
ESRS E1 E1-5 §37; §38; §AR 32(a), (c), (e) and (f)(2b)'Energy' is a sustainability matterfor E1 covered by ESRS 1 §AR
16. Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS E1 E1-5 §40 to §42'Energy' is a sustainability matterfor E1 covered by ESRS 1 §AR
16. Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed(2b)

3-3 Management of material topics
302-1 Energy consumption within theorganization

(1a)

(2b)

(302-1-a, b, c, e and g)

302-2 Energy consumption outside of
the organization

302-3 Energy intensity
302-4 Reduction of energy
consumption(2a)

GRI 301-1 requires a
breakdown by nonrenewable and renewablematerials used.

Differences exist between
the two in how energy
consumption data isaggregated anddisaggregated.

according to ESRS 1 §11 andpursuant to MDR-M.

302-5 Reductions in energy
requirements of products and services

GRI 303: Water
and Effluents 2018

'Energy' is a sustainability matterfor E1 covered by ESRS 1 §AR
16. Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
3-3 Management of material topics
ESRS E2 §AR 9 (b); E2-1 §12;
E2-2 §16 and §19; E2-3 §20;
ESRS E3 E3-1 §9; E3-2 §15, §17
to §18; E3-3 §20
303-1 Interactions with water as a
ESRS 2 SBM-3 §48 (a); MDR-T
shared resource§80 (f); ESRS E3 §8 (a); §AR 15(a); E3-2 §15, §AR 20
303-2 Management of water discharge- ESRS E2 E2-3 §24
related impacts

(2a)

(2b)

(303-2-iv)

303-3 Water withdrawal'Water withdrawals' is asustainability matter for E3
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.

(2b)

GRI 303-2 refers tominimum standards inwater quality discharges.
ESRS E2-3 refers to theconsideration of ecologicalthresholds in setting
pollution targets.

303-4 Water discharge

303-5 Water consumption
GRI 304:
Biodiversity 2016

3-3 Management of material topics

304-1 Operational sites owned, leased,managed in, or adjacent to, protectedareas and areas of high biodiversity
value outside protected areas'Water discharges' is asustainability matter for E3
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS E3 E3-4 §28 (a), (b), (d)and (e)ESRS E4 E4-1 §AR 1 (b) and (d);E4-2 §20 and §22; E4-3 §25 and§28 (a); E4-4 §29
ESRS E4 §16 (a) i; §19 (a); E4-5
§35

(2b)

(1a)

GRI 304-1-a-v requires
reporting the size for each
operational site. ESRS E45 requires an aggregatedfigure for all sites.

GRI 304-4 requires
quantitative data on thenumber of species affectedby each level of extinction
risk. ESRS E4-5 §40 (d) i isa narrative disclosure.
GRI 305 requirement 1.2
requires reporting the typeand scheme of which
offsets are part.

(304-1-a-iv and v)

304-2 Significant impacts of activities,
products and services on biodiversity

ESRS E4 E4-5 §35, §38, §39, §40(a) and (c)(304-2-a-i, ii, iii, iv, v and vi; 304-2-b)

304-3 Habitats protected or restored(304-3-a and b)

GRI 305:
Emissions 2016

ESRS E4 E4-3 §28 (b) and §AR
20 (e); E4-4 §AR 26 (a)304-4 IUCN Red List species andnational conservation list species with
habitats in areas affected by operations

ESRS E4 E4-5 §40 (d) i(1b)3-3 Management of material topics and
GRI 305 1.2

ESRS E1 E1-2 §22; E1-3 §26; E14 §33 and §34 (b); E1-7 §56 (b)and §61 (c); ESRS E2 §AR 9 (b);E2-1 §12; E2-2 §16 and §19; E2-3
§20

(2a)

305-1 Direct (Scope 1) GHG emissions

305-2 Energy indirect (Scope 2) GHG
emissions305-3 Other indirect (Scope 3) GHG
emissions305-4 GHG emissions intensity

ESRS E1 E1-6 §53; §54; §AR 39(c); §AR 53 (a)305-5 Reduction of GHG emissions

ESRS E1 E1-3 §29 (b); E1-4 §34(c); §AR 25 (b) and (c); E1-7 §56(305-5-a, c and 2.9.5)

305-6 Emissions of ozone-depleting
substances (ODS)

305-7 Nitrogen oxides (NOx), sulfur
oxides (SOx), and other significant air
emissions
GRI 306: Waste
2020

ESRS E1 E1-4 §34 (c); E1-6 §44(a); §46; §50; §AR 25 (b) and (c);§AR 39 (a) to (d); §AR 40; AR §43(c) to (d)ESRS E1 E1-4 §34 (c); E1-6 §44(b); §46; §49; §50; §AR 25 (b) and(c); §AR 39 (a) to (d); §AR 40;§AR 45 (a), (c), (d), and (f)ESRS E1 E1-4 §34 (c); E1-6 §44(c); §51; §AR 25 (b) and (c); §AR
39 (a) to (d); §AR 46 (a) (i) to (k)3-3 Management of material topics
306-1 Waste generation and significant
waste-related impacts'Pollution of air' is a sustainability
matter for E2 covered by ESRS 1§AR 16. Hence this GRI
disclosure is covered by MDR-P,
MDR-A, MDR-T, and/or as anentity-specific metric to bedisclosed according to ESRS 1§11 and pursuant to MDR-M.
ESRS E2 E2-4 §28 (a); §30 (b)and (c); §31; §AR 21; §AR 26
ESRS E5 §AR 7 (a); E5-1 §12;
E5-2 §17; E5-3 §21
ESRS 2 SBM-3 §48 (a), (c) ii andiv; ESRS E5 E5-4 §30

(1a)

(2b)

GRI 305-4 requires
reporting the intensity ratio
for Scope 3 GHG emissions
separately from Scope 1
and Scope 2. ESRS
requires reporting theintensity ratio for the total
GHG emissions.

306-2 Management of significant
waste-related impacts

ESRS E5 E5-2 §17 and §20 (e)and (f); E5-5 §40 and §AR 33 (c)(306-2-a and c)

306-3 Waste generated

ESRS E5 E5-5 §37 (a), §38 to §40(1b)306-4 Waste diverted from disposal

ESRS E5 E5-5 §37 (b), §38 and
§40

(1b)

ESRS E5 E5-5 §37 (c), §38 and
§40

(1a)
(1b)

'Pollution of air', 'Pollution ofwater', and 'Pollution of soil' aresustainability matters for E2
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS G1 G1-2 §12 and §15 (a)(2b)

ESRS G1 G1-2 §15 (b)(1b)(306-4-a, b, c, e)

306-5 Waste directed to disposal(306-5-a, b, c, e)

GRI 306: Effluentsand Waste 2016306-3 Significant spills

GRI 308: Supplier
Environmental
Assessment 2016

3-3 Management of material topics
308-1 New suppliers that werescreened using environmental criteria

GRI 306-3 requires
quantitative data (i.e, abreakdown of thecomposition of the waste in
metric tons). ESRS E5-5
§38 requires a narrative
disclosure.
See GRI 306-3.
GRI 306-4 requires a
breakdown between
incineration with energy
recovery and incineration
without energy recovery.
See also GRI 306-3.

GRI 308-1 requires
quantitative data on theextent of new suppliers
screened based on
environmental criteria.
ESRS G1-2 requires anarrative disclosure.

308-2 Negative environmental impacts
in the supply chain and actions taken

ESRS 2 SBM-3 §48 (c) i and iv(308-2-c)

GRI 401:
Employment 2016

3-3 Management of material topics

401-1 New employee hires andemployee turnover

ESRS S1 S1-1 §17; §20 (c); S1-2
§27; S1-4 §38; §39; §AR 40 (a);S1-5 §44; §47 (b) and (c); ESRSS2 §11 (c); S2-1 §14; §17 (c); S22 §22; S2-4 §32; §33 (a) and (b);§36; §AR 33; §AR 36 (a); S2-5
§39, §42 (b) and (c)ESRS S1 S1-6 §50 (c)(1a)

GRI 401-1-b requires
breakdowns by age group,
gender, and region.

(1a)

GRI 401-3 covers parental
leave. ESRS S1-15 covers
family-related leave.
Parental leave is one of thetypes of family-related
leave. GRI 401-3-a requiresa breakdown by gender forthe parental leave.

(401-1-b)

401-2 Benefits provided to full-time
employees that are not provided totemporary or part-time employees

ESRS S1 S1-11 §74; §75; §AR 75(401-2-a-ii, a-iii, a-iv, a-v and b)

401-3 Parental leave

ESRS S1 S1-15 §93(401-3-a and b)

GRI 402:
3-3 Management of material topics
Labor/Management
Relations 2016402-1 Minimum notice periods
regarding operational changes

ESRS S1 S1-1 §17; §20 (c); S1-2
§27; S1-4 §38; §39; §AR 40 (a);S1-5 §44; §47 (b) and (c); ESRSS2 §11 (c); S2-1 §14; §17 (c); S22 §22; S2-4 §32; §33 (a) and (b);§36; §AR 33; §AR 36 (a); S2-5
§39, §42 (b) and (c)'Social dialogue' and 'Collective
bargaining' are sustainability
matters for S1 covered by ESRS 1§AR 16. Hence this GRI
disclosure is covered by MDR-P,
MDR-A, MDR-T, and/or as an(2b)

entity-specific metric to bedisclosed according to ESRS 1§11 and pursuant to MDR-M.

GRI 403:
Occupational
Health and Safety
2018

3-3 Management of material topics

403-1 Occupational health and safety
management system

ESRS S1 S1-1 §17; §20 (c); S1-2
§27; S1-4 §38; §39; §AR 40 (a);S1-5 §44; §47 (b) and (c); ESRSS2 §11 (c); S2-1 §14; §17 (c); S22 §22; S2-4 §32; §33 (a) and (b);§36; §AR 33; §AR 36 (a); S2-5
§39, §42 (b) and (c)ESRS S1 S1-1 §23(1a)(403-1-a)403-2 Hazard identification, risk
assessment, and incident investigation

ESRS S1 S1-3 §32 (b) and §33(403-2-b)

403-3 Occupational health services
403-4 Worker participation,
consultation, and communication on
occupational health and safety403-5 Worker training on occupational
health and safety'Health and safety' and 'Training
and skills development' aresustainability matters for S1
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.

(2b)

GRI 403-1-a requires
reporting the legal
requirements andmanagement systemstandards on which thesystem is based. This
information is not requiredin ESRS as this is regulated
within the European Union.

403-6 Promotion of worker health403-7 Prevention and mitigation ofoccupational health and safety impacts
directly linked by business
relationships
403-8 Workers covered by an
occupational health and safety
management system'Social protection' is asustainability matter for S1
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS S2 S2-4 §32 (a)(2b)

ESRS S1 S1-14 §88 (a); §90(2c)

ESRS S1 S1-4, §38 (a); S1-14§88 (b) and (c); §AR 82

(1a)
(2c)

GRI 403-9-c-iii and drequire reporting on the useof the hierarchy of controls.

ESRS S1 S1-4, §38 (a); S1-14§88 (b) and (d); §89; §AR 82

(1a)
(2c)

See GRI 403-9.

(403-8-a and b)

403-9 Work-related injuries(403-9-a-i, a-iii, b-i, b-iii, c-iii, d, e)

403-10 Work-related ill health(403-10-a-i, a-ii, b-i, b-ii, c-iii)

GRI 404: Training
and Education
2016

3-3 Management of material topics

404-1 Average hours of training peryear per employee

ESRS S1 S1-1 §17; §20 (c); S1-2
§27; S1-4 §38; §39; §AR 40 (a);S1-5 §44; §47 (b) and (c); ESRSS2 §11 (c); S2-1 §14; §17 (c); S22 §22; S2-4 §32; §33 (a) and (b);§36; §AR 33; §AR 36 (a); S2-5
§39, §42 (b) and (c)ESRS S1 S1-13 §83 (b) and §84

404-2 Programs for upgrading
employee skills and transition
assistance programs

ESRS S1 S1-1 §AR 17 (h)(404-2-a)

GRI 405: Diversity
and Equal
Opportunity 2016404-3 Percentage of employees
receiving regular performance andcareer development reviews

ESRS S1 S1-13 §83 (a) and §84

3-3 Management of material topics

ESRS S1 S1-1 §17; §20 (c); S1-2
§27; S1-4 §38; §39; §AR 40 (a);S1-5 §44; §47 (b) and (c); ESRSS2 §11 (c); S2-1 §14; §17 (c); S22 §22; S2-4 §32; §33 (a) and (b);§36; §AR 33; §AR 36 (a); S2-5
§39, §42 (b) and (c)ESRS S1 §24 (a)ESRS 2 GOV-1 §21 (d); ESRS S1
S1-6 §50 (a); S1-9 §66 (a) to (b);S1-12 §79

3-3 Management of material topics
405-1 Diversity of governance bodies
and employees(405-1-a-i and iii, 405-1-b)

GRI 406: Nondiscrimination
2016405-2 Ratio of basic salary andremuneration of women to men
3-3 Management of material topics

406-1 Incidents of discrimination andcorrective actions taken

ESRS S1 S1-16 §97 and §98
ESRS S1 S1-1 §17; §20 (c); §24(a) and (d); S1-2 §27; S1-4 §38;
§39; §AR 40 (a); S1-5 §44; §47(b) and (c); ESRS S2 §11 (c); S21 §14; §17 (c); S2-2 §22; S2-4
§32; §33 (a) and (b); §36; §AR 33;§AR 36 (a); S2-5 §39, §42 (b) and(c); ESRS S4 §10 (b); S4-1 §13;
§16 (c); S4-2 §20; S4-4 §31; §32(a) and (b); §35; §AR 30; §AR 33(a); S4-5 §38; §41 (b) and (c)ESRS S1 S1-17 §97, §103 (a),§AR 103(1a)

GRI 405-1-b requires
breakdowns by employee
category.

GRI 407: Freedomof Association andCollective
Bargaining 2016

3-3 Management of material topics

407-1 Operations and suppliers inwhich the right to freedom of
association and collective bargaining
may be at risk

GRI 408: Child
Labor 2016

3-3 Management of material topics

408-1 Operations and suppliers at
significant risk for incidents of child
labor

ESRS S1 S1-1 §17; §20 (c); S1-2
§27; S1-4 §38; §39; §AR 40 (a);S1-5 §44; §47 (b) and (c); ESRSS2 §11 (c); S2-1 §14; §17 (c); S22 §22; S2-4 §32; §33 (a) and (b);§36; §AR 33; §AR 36 (a); S2-5
§39, §42 (b) and (c)'Freedom of association' and'Collective bargaining' aresustainability matters for S1 andS2 covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS S1 S1-1 §17; §20 (c); §22;
S1-2 §27; S1-4 §38; §39; §AR 40(a); S1-5 §44; §47 (b) and (c);ESRS S2 §11 (c); S2-1 §14; §17(c); §18; S2-2 §22; S2-4 §32; §33(a) and (b); §36; §AR 33; §AR 36(a); S2-5 §39, §42 (b) and (c)ESRS S1 §14 (g); S1-1 §22 ESRSS2 §11 (b); S2-1 §18

(2b)

(2a)

GRI 408-1-b-i requires
reporting the types ofsuppliers at risk.

(2a)

See GRI 408-1.

(408-1-a-i, b, c)

GRI 409: Forced orCompulsory Labor
2016

3-3 Management of material topics

409-1 Operations and suppliers at
significant risk for incidents of forced orcompulsory labor

ESRS S1 S1-1 §17; §20 (c); §22;
S1-2 §27; S1-4 §38; §39; §AR 40(a); S1-5 §44; §47 (b) and (c);ESRS S2 §11 (c); S2-1 §14; §17(c); §18; S2-2 §22; S2-4 §32; §33(a) and (b); §36; §AR 33; §AR 36(a); S2-5 §39, §42 (b) and (c)ESRS S1 §14 (f); S1-1 §22 ESRSS2 §11 (b); S2-1 §18

GRI 410: Security
Practices 2016

3-3 Management of material topics

410-1 Security personnel trained inhuman rights policies or procedures

GRI 411: Rights ofIndigenous
Peoples 2016

3-3 Management of material topics

411-1 Incidents of violations involving
rights of indigenous peoples

GRI 413: Local
Communities 2016

3-3 Management of material topics

413-1 Operations with local community
engagement, impact assessments, anddevelopment programs

ESRS S3 §9 (b); S3-1 §12, and§16 (c); S3-2 §21; S3-4 §32 (a) to(d), §33 (a) and (b), §35, 36; §AR31, §AR 34 (a); S3-5 §39, §43'Security-related impacts' is asustainability matter covered forS3 covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS S3 §9 (b); S3-1 §12, §15
and §16 (c); S3-2 §21; S3-4 §32(a) to (d), §33 (a) and (b), §35, 36;§AR 31, §AR 34 (a); S3-5 §39,
§43
ESRS S3 S3-1 §16 (c), AR 12;
S3-4 §30, §32 (b), §33 (b), §36

ESRS S3 §9 (b); S3-1 §12, and§16 (c); S3-2 §21; S3-4 §32 (a) to(d), §33 (a) and (b), §35, 36; §AR31, §AR 34 (a); S3-5 §39, §43
ESRS S3 S3-2 §19; S3-3 §25; S34 §AR 34 (c)

(2b)

(1b)

GRI 411-1 requires
quantitative data on thenumber of incidents. ESRSS3 requires narrative
disclosures.

(1b)

GRI 413-1 requires
quantitative data on
operations with
implemented local
community engagement,
impact assessments,
and/or development
programs. ESRS S3
includes narrative
disclosures.

413-2 Operations with significant actualand potential negative impacts on local
communities

ESRS 2 SBM-3 48 (c); ESRS S3§9 (a) i and (b)(413-2-a-ii)

GRI 414: SupplierSocial Assessment
2016

3-3 Management of material topics

ESRS G1 G1-2 §12 and §15 (a)414-1 New suppliers that werescreened using social criteria

ESRS G1 G1-2 §15 (b)414-2 Negative social impacts in the
supply chain and actions taken

ESRS 2 SBM-3 §48 (c) i and iv(1b)

GRI 414-1 requires
quantitative data on theextent of new suppliers
screened based on social
criteria. ESRS G1-2
requires a narrative
disclosure.

(414-2-c)

GRI 415: Public
Policy 2016
GRI 416: Customer
Health and Safety
2016

3-3 Management of material topics

ESRS G1 G1-5 §27

415-1 Political contributions
3-3 Management of material topics

ESRS G1 G1-5 §29 (b)ESRS S4 §10 (b); S4-1 §13, §16(c); S4-2 §20; S4-4 §31; §32 (a)and (b), §35, §AR 30, §AR 33 (a);S4-5 §38, §41 (b) and (c)'Personal safety of consumers andend-users' is a sustainability
matter for S4 covered by ESRS 1§AR 16. Hence this GRI
disclosure is covered by MDR-P,
MDR-A, MDR-T, and/or as anentity-specific metric to bedisclosed according to ESRS 1§11 and pursuant to MDR-M.
ESRS S4 S4-4 §35

416-1 Assessment of the health andsafety impacts of product and service
categories

416-2 Incidents of non-complianceconcerning the health and safety
impacts of products and services

(2b)

(1b)

GRI 416-2 requires
quantitative data on thenumber of incidents andbreakdowns by types ofincidents of non-compliance. ESRS S4-4
requires a narrative
disclosure.
GRI 417: Marketingand Labeling 2016

3-3 Management of material topics

417-1 Requirements for product andservice information and labeling417-2 Incidents of non-complianceconcerning product and service
information and labeling

GRI 418: Customer
Privacy 2016

ESRS S4 §10 (b); S4-1 §13, §16(c); S4-2 §20; S4-4 §31; §32 (a)and (b), §35, §AR 30, §AR 33 (a);S4-5 §38, §41 (b) and (c)'Information-related impacts for
consumers and end-users' is asustainability matter for S4
covered by ESRS 1 §AR 16.
Hence this GRI disclosure iscovered by MDR-P, MDR-A,
MDR-T, and/or as an entityspecific metric to be disclosed
according to ESRS 1 §11 andpursuant to MDR-M.
ESRS S4 S4-4 §35

(2b)

(1b)

417-3 Incidents of non-complianceconcerning marketing communications

ESRS S4 S4-4 §35(1b)

3-3 Management of material topics

ESRS S4 §10 (b); S4-1 §13 and§16 (c); S4-2 §20; S4-4 §31, §32(a) and (b), §35, §AR 30, §AR 33(a); S4-5 §38, §41 (b) and (c)ESRS S4 S4-3 §AR 23; S4-4 §35(1a)418-1 Substantiated complaints
concerning breaches of customer
privacy and losses of customer data

GRI 417-2 requires
quantitative data on thenumber of incidents andbreakdowns by types ofincidents of noncompliance. ESRS S4-4
requires a narrative
disclosure.
See GRI 417-2.

GRI 418-1 requires further
granularity on the type ofcomplaints and the numberof identified leaks, thefts, orlosses of customer data.

Notes legend(1a) Differences in granularity: GRI requires further breakdowns or granularity.
(1b) Differences in data type: GRI requires quantitative disclosure and ESRS requires qualitative disclosure.
(2a) Differences in scope: GRI disclosure is broader and/or more specific than ESRS.
(2b) Differences in scope: GRI and ESRS disclosures have the same disclosure objective but differ in how data points are formulated.
(2c) Differences in scope: GRI 403 covers employees and workers who are not employees but whose work and/or workplace is controlled
by the organization. ESRS S1-14 covers employees and non-employee workers (people with contracts with the undertaking to supply
labour (“self-employed people”) or people provided by undertakings primarily engaged in “employment activities” (NACE Code N78)). For
fatalities, ESRS S1-14 covers workers working on the undertaking’s sites.
(3) Difference in definition of non-employees: GRI 2-8 covers workers who are not employees and whose work is controlled by theorganization. ESRS S1-7 covers non-employee workers (people with contracts with the undertaking to supply labour (“self-employedpeople”) or people provided by undertakings primarily engaged in “employment activities” (NACE Code N78)).