Disclosure focus
This disclosure asks an organisation to explain how it engages with workers in its value chain and how those workers can raise concerns or complaints. In practice, the report should show whether the organisation has arrangements that are available to the relevant workers, how those arrangements work, and whether they are used to identify and address issues affecting people in the value chain.
The practical focus is on coverage and accessibility, not just on describing a policy or a few flagship examples. An organisation should be clear about which parts of its operations and value chain are covered, whether the mechanisms are available in the places and contexts where workers are actually located, and how it knows the process is functioning in reality rather than only on paper.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show S2-2 sub-elements (LRA working checklist)
Describe how you engage each identified group.
State whether any formal agreement is in place, and what it covers.
List the ways people can engage with you.
Explain how easy those channels are to use.
Show which channels are available.
Set out the indicators you use to track performance.
Say whether a formal grievance or feedback route exists.
Report the share of cases resolved.
Report how quickly you respond.
Report how many cases were fixed.
Explain the steps you use to put things right.
How to prepare it
1Set the reporting boundary first. Decide which supplier-related groups, sites, contracts, and operating relationships sit inside the disclosure period, then keep that scope consistent across the whole response.
2List the people and organisations covered, and separate the different ways you engage with them. Capture which groups were identified, what contact methods were used, and whether any formal arrangements exist for that engagement, together with the reach of those arrangements.
3Map the channels that are actually available. Record whether there is a formal route for raising issues, how people can access it, and any practical limits or conditions that affect use.
4Gather the operating evidence for the channel. Pull together the measures you use to track performance, including how many matters are closed, how quickly responses are given, and any other figures or narrative needed to explain how the channel works in practice.
5Describe how follow-up and remedy are handled. Summarise the process used to address cases, then state how many matters were put right during the period, using a clear and internally consistent basis for any counts or descriptions.
6Check the final draft against the source material before sign-off. Confirm that every required item is covered, note any exclusions or changes in scope or method, and make sure the wording matches the official source in substance without copying it.
Request the data
Request supplier engagement and issue-handling evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do we show which supplier groups we engage, what channels they can use to raise issues, and how those issues are tracked, resolved and remediated?
Use your team’s own terms first, then map them to the reporting fields. For example, if you talk about supplier forums, hotline cases, site visits, escalation logs or corrective actions, keep those labels in the request and only translate them afterwards for the disclosure pack. This is a training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the ESRS S2-2 engagement and grievance mechanism data for the period, including stakeholder groups, channels, accessibility, KPIs, response times, resolution rates, remediation processes and remediated cases.
Why it fails: It uses framework language that many operational teams do not use day to day, so the owner may not know which records to pull. It also bundles several ideas together without pointing to the team’s actual trackers, logs or process names, which makes the request harder to action and harder to evidence.
Better request
Please send the supplier engagement and issue-handling records for [reporting period] covering [business boundary]. I need the groups you work with, the ways they can raise concerns, whether there is a formal route and what it covers, the channels available, how accessible they are, the KPIs you already track, how you calculate response time and closure rate, and any remediation notes for cases closed in the period. Please use your own tracker or case log names and attach the source file or link.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Explain how the organisation identified the affected groups, what it counts as an engagement route or complaint channel, and how it measured coverage, accessibility, performance and case handling.
Context note
Set out what the figures show about how people can raise issues, how the organisation responds, whether arrangements are formalised, and how many matters are resolved through remediation.
Fluctuation statement
If the figures moved materially, note whether the change came from adding or removing channels, changes in who was covered, shifts in accessibility, or differences in how many cases were received and resolved.
Content index entry
S2-2 Engagement & Grievance Mechanisms — [location / page] / [notes]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The team asks the wrong business owner for the channel list or case data, so the figures come from someone who does not run the worker contact route or the case-handling process.
Framework language only
The request is sent in ESRS-style terms instead of the organisation’s own labels, and the recipient cannot map the ask to the hotline, case log, or local escalation route they actually manage.
Scope left vague
No one fixes which worker groups, sites, or operating units are in scope, so the data pull mixes covered and non-covered populations.
Wrong time basis
The team pulls records using a different cut-off or reporting window from the one used for the rest of the report, which makes the channel and case data inconsistent.
Mixed counting basis
One extract counts unique people while another counts contacts or cases, so the numbers cannot be compared or rolled up cleanly.
Source labels lost
The original system tags, case IDs, or channel names are stripped out during export, so the team cannot trace each figure back to the underlying record.
Populations merged
Separate worker groups that should stay distinct are combined into one file, which hides differences in how engagement or complaints are handled.
Missing evidence trail
The file is saved without the supporting notes, extract date, or reviewer sign-off, so nobody can show how the number was built or approved.
Where judgement is often needed
Which worker groups sit inside the reporting boundary after a buy-in or sale
Use the reporting period boundary you have set for the rest of the report, explain any added or removed sites or workforces, and state whether the engagement and complaint data include the changed population for the full year or only from the date of transfer.
How to handle local labels that do not map neatly across countries
Group similar worker categories under one plain description where local job titles differ, but explain the mapping you used so readers can see which people were counted together and where local practice led to a different split.
Whether to include people just outside the formal workforce but still affected
Decide and disclose whether you have included contractors, agency staff, seasonal workers or other near-boundary groups in the channels and case counts, and make clear the rule used to include or exclude them.
What counts as a channel versus a full complaint route
Separate simple ways to raise a concern from a structured case-handling route, and explain if a hotline, manager route, union route or digital form is treated as one channel or several in your figures.
How to describe access where language, literacy or disability support differs by location
State the practical access features in each operating area, and if support varies by country or site, explain the main differences rather than forcing a single global description that hides local limits.
Which performance measures are based on actual case records and which are estimated
Use recorded case data where available, but if you need estimates for timing, closure or response measures, say so clearly and explain the method and any material assumptions behind the estimate.
How to set the time cut-off for response and closure measures
Choose one consistent cut-off date and one timing basis for all locations, then explain whether you measure from receipt, acknowledgement or first action, and whether late-open cases are left open or carried into the next period.
How to present very small numbers without exposing individuals
Round or combine small counts where needed to protect privacy, but disclose the rule you used and make sure the published totals still reconcile to the underlying case population.
How to report outcomes when a case is partly resolved
Define whether a matter is counted as resolved only when every action is finished or when the main issue is closed, and explain how you treat cases with follow-up actions, partial fixes or ongoing monitoring.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We used several routes to hear from workers in our own operations and from people in the supply chain who may be affected, and we set out which groups were reached and how each route worked. Where we had formal arrangements with worker representatives, we noted that they covered our direct workforce and key contractor sites; we also kept a separate complaints route open to all relevant people, with access through site noticeboards, a phone line, email, and a web form, plus language support and options for shift workers and people with limited digital access. - The complaints route was available across all sites, could be used without charge, and was designed to be reachable by workers, contractors, and other affected people; we tracked the number of matters raised, the share resolved, and the time taken to give an initial reply. - During the period, 48 matters were logged, 39 were closed through the process, and 44 received a first response within 10 working days; we also used a separate remedy process for confirmed cases, and 12 cases were fully put right.
Illustrative only: shows how to describe who was engaged, the methods used, whether formal arrangements existed and what they covered, the channels open for concerns, how accessible they were, the key measures tracked, the share resolved, the response timing, and how remedy was handled.
Illustrative (synthetic) example — Retail logistics
We maintained direct dialogue with warehouse teams, delivery drivers, and labour-hire staff, using different formats so people could speak up in ways that suited their work pattern. We also had written agreements with elected worker representatives for our distribution centres, covering the permanent warehouse workforce and agency staff on those sites; alongside that, we ran a grievance route that was open through kiosks, QR codes, a hotline, and in-person HR drop-ins, with translation support and an option to submit anonymously. - The route was available at every major site and was designed to be usable by night-shift staff and people without company devices; we monitored how many issues came in, how many were settled, and how quickly people heard back. - In the year, 27 issues were raised, 20 were resolved, and 24 got an initial reply within 7 working days; for matters needing correction, we used a formal remedy path and completed 9 cases.
Illustrative only: shows a second plausible reporter with different channels and workforce mix, while still covering engagement groups and methods, formal arrangements and scope, open channels, accessibility, tracked measures, resolution share, reply timing, and remediation outcomes.
How companies report S2-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Bakkafrost P/F
Food Production — Animal Source · Faroe Islands · 2025
Bakkafrost P/F’s Integrated Annual Report 2025 includes a reference to processes for engaging with value chain workers about impacts and for remediating negative impacts, as noted on page 74. However, the report lacks clear, quotable evidence detailing how these engagement processes are implemented or how remedies for human rights impacts are provided or enabled. Additionally, no further narrative or methodological explanation on this disclosure is found elsewhere in the report.
Moncler S.p.A.
Textiles, Apparel, Footwear and Luxury Goods · Italy · 2024
Moncler S.p.A.'s 2024 Annual Report includes a description of processes to remediate negative impacts and channels for value chain workers to raise concerns, specifically referenced on page 137 (p.137). The report also mentions processes for engaging with own workers and their representatives about impacts on page 233 (p.233), and processes to remediate negative impacts for own workers on page 105 (p.105). However, no additional detailed narrative or methodology related to these processes was found elsewhere in the report, indicating limited coverage beyond these references.
Fluidra, S.A.
Electrical Equipment and Machinery · Spain · 2025
Fluidra’s 2025 Integrated Annual Report provides some coverage of processes for engaging with value chain workers about impacts, notably on page 300, where such processes are described. There is partial information on remediation processes, with page 205 mentioning reviews of compliance with corrective actions but without providing headline values. However, the report lacks clear or quotable evidence on several narrative items related to this disclosure, with many datapoints not found or unclear in the document.
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Scenarios to work through
A manufacturer has mapped two worker groups for direct dialogue this year: site employees and agency workers at its main plant. It uses toolbox talks for one group and a worker committee for the other, but the committee only covers the day shift.
QHow should the preparer decide whether the description of dialogue routes is complete, and what else needs to be checked before sign-off?
Reveal model answer →Hide answer ↑The preparer should confirm that the write-up names every worker group the company has identified for direct contact and explains the way each group is engaged. It should also be checked whether any agreement with those groups limits the scope of the dialogue, and if so, that scope needs to be described clearly rather than implied.
Why this matters · List the relevant groups and the way each is engaged, then state any agreed limits on what the dialogue covers.
A food processor has a hotline for complaints from workers and contractors, but it is only available in the local language and can be used only during office hours. The team is unsure whether that is enough to describe the route as accessible.
QWhat judgement should the preparer make about the complaint route, and what detail should be included in the disclosure?
Reveal model answer →Hide answer ↑The preparer should not treat a channel as accessible just because it exists. The description should explain how people can actually use it in practice, including any language, timing, location, or other access features that affect whether workers and other affected people can reach it without unreasonable barriers.
Why this matters · Accessibility is about practical use, not just the existence of a reporting route.
A retailer tracks the number of issues raised, the share closed within target, and the average days to first reply. One business unit also reports a separate measure for repeat complaints, and the reporting team wonders whether that extra metric should replace the others.
QHow should the preparer handle the performance measures for the grievance route?
Reveal model answer →Hide answer ↑The preparer should keep the measures that show how the route is being used and how well it is working, including the volume of cases, how many are resolved, and how quickly people get a response. Extra indicators can be added, but they should not crowd out the core picture of use, closure, and timeliness unless the company can still explain those three aspects clearly.
Why this matters · Use indicators that show uptake, closure, and speed of response, then add extras only if the core story remains clear.
A logistics company says it has a process to fix worker complaints, but in practice supervisors handle issues informally and there is no written path for cases that need escalation. The team has also closed 18 of 30 logged cases this year, but it is unclear whether those 18 were actually put right.
QWhat should the preparer conclude about the remediation description and the case count?
Reveal model answer →Hide answer ↑The preparer should describe the actual process used to put things right, including how a case moves from intake to follow-up and escalation where needed. The count of cases fixed should only cover matters that were genuinely remedied, not simply closed in a register, so the team needs to separate administrative closure from real corrective action.
Why this matters · Explain the real fix-up process and distinguish closed files from issues that were actually put right.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
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FAQ
Questions this page answers
How do I use the S2-2 page to prepare a first draft disclosure on workers in the value chain engagement and grievance routes?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints list. The page is designed to help you turn those inputs into a draft narrative and, where relevant, a simple table or content-index line.
What data do I need to collect for S2-2 before I can draft the disclosure?+−
The page lists the datapoints to prepare, including engagement routes, stakeholder groups, engagement approach, agreed terms, grievance routes, formal process, access conditions, complaint metrics, resolved share, reply timing, fix-up process and closed remedies. Use that list as your collection checklist so you can gather the right inputs before drafting.
How should I decide the scope and methodology for an S2-2 disclosure using this page?+−
Use the step-by-step preparation section to define what is in scope and then align your data collection to the listed datapoints. The page does not set a one-size methodology, so the practical approach is to document your own scope choices clearly and keep them consistent across the narrative, table and evidence pack.
Who should own the S2-2 data and evidence pack in practice?+−
The page is aimed at sustainability and ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can explain the data and provide evidence. In practice, assign a named owner for the disclosure, a data owner for the underlying metrics, and a reviewer for assurance readiness.
What should go into the S2-2 evidence pack to make the disclosure assurance-ready?+−
The page includes an evidence pack with five items for assurance readiness, alongside five assurance claims to verify. Use those materials to show how the figures and narrative were built, and keep the supporting documents organised so a reviewer can trace each claim back to source evidence.
What are the common mistakes to avoid when drafting S2-2?+−
The page lists common reporting gaps and mistakes, so it is useful as a pre-submission check. A practical use is to compare your draft against the datapoints, the evidence pack and the assurance claims to spot missing detail, weak support or inconsistent wording.
How do I use the synthetic example disclosure on the S2-2 page without copying it blindly?+−
Treat the example as a model for structure and level of detail, not as a template to copy. The page says the example is synthetic and includes a quantitative table, so you can use it to see how a draft might read while still tailoring the content to your own data.
Can I use the S2-2 workbook and printable Library Card to build my disclosure?+−
Yes. The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format, which are there to support preparation and assurance readiness. Use them to organise inputs, track evidence and shape the draft output.
What does the draft-output section help me produce for S2-2?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line. That makes it easier to turn collected data into a usable draft rather than starting from a blank page.
Where can I find real company examples for S2-2 on the page?+−
The page includes a 'From company reports' table that links to real published reports at the pages where the topic is disclosed. Use it to see how others have presented similar information, but keep your own disclosure grounded in your organisation’s data and scope.
More questions this page can help with
S2-2 workers in the value chain disclosure checklist for engagement routes and grievance routesHow to prepare S2-2 stakeholder groups and engagement approach data for reportingS2-2 agreed terms and agreement coverage: what evidence should I collect?S2-2 complaint metrics, resolved share and reply timing: how do I draft the numbers?How do I document access conditions, formal process and fix-up process for S2-2?S2-2 assurance claims and evidence pack: what should be in the file?Common mistakes in S2-2 workers in the value chain disclosureHow to use the S2-2 Prep & Assurance workbook and Library CardS2-2 example disclosure table: how to adapt a synthetic example to my dataS2-2 draft narrative starters and content-index line examplesWhere to find company report examples for S2-2 workers in the value chainS2-2 disclosure preparation steps for ESG managers and HR data owners
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