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GRI 205: Anti-corruption · 2016

Disclosure GRI 205-2

Communication and training about anti-corruption policies and procedures

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

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Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI

To prepare this disclosure

14datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain how it communicates its anti-corruption policies and procedures, and how it trains the people who need to know them. In practice, the focus is on whether the organisation has made these expectations known in a way that is relevant to the workforce and other covered people, rather than simply having the policy written down.

The practical question is how far that communication and training reach across the organisation. Report on coverage across operations, functions, locations, and relevant worker groups, not just a few flagship sites or senior teams. If the approach differs by role or geography, make that clear so readers can see where the policy is embedded and where gaps may remain.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Have you fixed which region or operating area this count will cover, so you do not mix locations in one figure? For each group you report on, have you agreed who is included in the headcount and percentage: board members, staff, business partners, or other external parties? Have you decided whether the numbers will reflect people who were told about the anti-bribery rules, people who completed training, or both, and kept those two sets separate? Have you chosen the cut-off date or reporting period for the counts, and will every total and percentage use the same basis? Can you trace each number back to a source record, such as a training log, communication register, or attendance list, without relying on estimates? Have you settled the wording for any non-standard groupings, such as staff grades or partner types, so the labels match your internal records?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Geographic region The region used to group the reported population, with the same geography applied consistently across the disclosure. Evidence required: reporting taxonomy, internal data extract, or mapping note showing how the region field is defined and assigned. Reporting / ESG data owner

Governance bodies briefed The headcount of board and committee members who were given the anti-corruption policy and procedure briefing during the reporting period. Evidence required: board/committee distribution log, training or briefing register, or signed acknowledgement list. Company Secretary / Compliance

Board briefing rate The share of board and committee members who were given the anti-corruption policy and procedure briefing, calculated from the same member population as the count. Evidence required: calculation sheet tying the numerator to the governance body member total and showing the percentage formula. Reporting / ESG data owner

Employee grouping The employee group or category used to split the workforce for this disclosure, using the organisation’s own classification consistently. Evidence required: HRIS category list, workforce segmentation note, or reporting mapping from HR codes to disclosure categories. HR / People analytics

Employees briefed The headcount of employees who were given the anti-corruption policy and procedure briefing during the reporting period. Evidence required: HRIS training completion extract, learning system report, or communication acknowledgement log. HR / Learning and development

Employee briefing rate The share of employees who were given the anti-corruption policy and procedure briefing, using the same employee population as the count. Evidence required: calculation workbook showing employee total, briefed employee count, and percentage formula. HR / Reporting

Partner type The kind of external business partner included in the disclosure, using the organisation’s own partner grouping. Evidence required: supplier/partner classification list, procurement taxonomy, or contract register mapping note. Procurement / Third-party risk

Partners briefed The headcount of business partners who were given the anti-corruption policy and procedure briefing during the reporting period. Evidence required: third-party communication log, supplier portal report, or acknowledgement records from the partner population. Procurement / Third-party risk

Partner briefing rate The share of business partners who were given the anti-corruption policy and procedure briefing, calculated from the same partner population as the count. Evidence required: calculation sheet showing partner total, briefed partner count, and percentage formula. Procurement / Reporting

Other outreach method A plain description of how the anti-corruption policy and procedure were shared with any other people or organisations not covered by the main groups above. Evidence required: communication plan, mailing list, event record, or outreach log describing the channel and audience. Compliance / Communications

Governance training count The headcount of board and committee members who completed anti-corruption training during the reporting period. Evidence required: learning management system completion report, attendance register, or signed training record for the governance population. Company Secretary / Compliance

Governance training rate The share of board and committee members who completed anti-corruption training, using the same governance population as the count. Evidence required: calculation workbook showing governance member total, trained member count, and percentage formula. Reporting / Compliance

Employees trained The headcount of employees who completed anti-corruption training during the reporting period. Evidence required: learning management system completion extract or HR training report tied to the employee population. HR / Learning and development

Employee training rate The share of employees who completed anti-corruption training, using the same employee population as the count. Evidence required: calculation sheet showing employee total, trained employee count, and percentage formula. HR / Reporting

＋ Show GRI 205-2 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first. Decide which region, governance members, employees and business partners are in scope for this disclosure, and keep that scope consistent across every figure and narrative you prepare.

2Define the groups and labels you will use. Separate the board-level group, employee categories and partner types clearly so each count can be tied back to the right population and no person or organisation is counted in the wrong bucket.

3Gather support for each number. Use attendance logs, training records, communication registers, distribution lists or similar internal records that show who was reached, who was trained, and which category they belong to.

4Build the reported outputs. For each group, prepare the total reached and the related percentage, and add a short explanation for any other people or organisations that received the policies and procedures through a different route.

5Record any exclusions or changes in method. If a group is left out, reclassified, or measured differently from prior periods, note the reason so the reported totals and percentages can be understood in context.

6Check the final pack against the source material. Confirm that the figures, categories and narrative match the underlying records and the official disclosure source before sign-off.

Request the data

Request anti-corruption communication and training evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which groups were told about the anti-bribery / anti-corruption policy set, and which groups completed related training, during the reporting period?

Use your organisation’s own labels first, then map them to the reporting categories. For example, you may track board packs, policy acknowledgements, code-of-conduct rollouts, supplier onboarding, or ethics training rather than the framework’s wording. Please check the source disclosure before sign-off.

Weak request

Please provide the GRI 205-2 data for anti-corruption communication and training.

Why it fails: This is too framework-led and does not tell the owner which internal populations, systems, or counting rules to use. It also leaves out the practical split between communication and training, so the response is likely to be incomplete or hard to reconcile.

Better request

Please provide the anti-bribery / anti-corruption rollout and training figures for [period], using your own board, staff, and third-party labels. Include the source system, the total population for each group, how many were reached by the communication activity, how many completed training, the percentages, and a short note on any other audiences and how they were covered.

Formal email template

Subject: Request for anti-corruption communication and training data

Hello [name],

Could you please share the figures and supporting evidence for our anti-bribery / anti-corruption communications and training for [reporting period]?

We need this for the following internal groups, using your own system labels where possible:
- [board / committee group]
- [employee groups]
- [business partner groups]
- [other audiences, if any]

Please include:
- the total number in each group
- the number reached by the communication activity
- the percentage reached
- the number who completed training
- the percentage trained
- a short note on any other audiences and how they were reached
- the source system or record set used
- the counting rule and any exclusions

If helpful, you can return this in a table and add a short note on how the figures were compiled. Please adapt this to your organisation’s own terms, and check the source disclosure before sign-off.

Many thanks,
[preparer name]
[team]
[contact details]

Short Teams / Slack version

Hi [name] — could you send over the anti-bribery / anti-corruption comms and training numbers for [period], plus the source file or system extract? Please use your own group labels and include any notes on how you counted them. Thanks.

Industry examples

Financial services

Context. The compliance team tracks board briefings, staff attestations, and mandatory ethics e-learning in separate systems.

Adapted request. Please share the anti-bribery / anti-corruption communication and training extract for [period], split by board members, staff groups, and relevant third parties. Use the labels from the board portal, LMS, and third-party onboarding tracker, and include the source system, denominator, counts reached, counts trained, and percentages.

Example response. Board members: 12 total, 12 briefed, 100%; staff: 4,850 total, 4,760 notified, 98.1%, 4,702 trained, 96.9%; third parties: 1,240 total, 1,180 sent the policy pack, 95.2%. Source systems: board portal, LMS, supplier onboarding tracker.

Manufacturing

Context. The business uses site-level induction records, contractor onboarding logs, and supplier code acknowledgements.

Adapted request. Please provide the anti-corruption induction, policy notice, and training figures for [period] across site employees, contractors, and key suppliers. Use your operational labels, and include the system extract, the total population in each group, the number who received the notice, the number trained, and the percentages.

Example response. Site employees: 2,300 total, 2,280 received the policy notice, 99.1%, 2,150 trained, 93.5%; contractors: 640 total, 610 received the notice, 95.3%, 540 trained, 84.4%; suppliers: 410 total, 390 received the supplier code pack, 95.1%. Source systems: induction log, contractor register, supplier onboarding file.

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

State which groups are included in the counts, how each audience is defined, and whether the figures cover the full reporting period, a point-in-time snapshot, or only those who were actually reached or trained.

Context note

Explain what the coverage figures show about how widely the anti-corruption approach has been rolled out across leadership, staff and external partners, and note any groups where reach or training is still incomplete.

Fluctuation statement

If the numbers moved materially from the prior period, link the change to practical causes such as a wider rollout, new joiners, refreshed training, a changed partner base, or a different way of counting the audience.

Content index entry

GRI 205-2 Communication and training about anti-corruption policies and procedures — [location / page] / [notes]

Download Centre

Preparation tools & forms

Professional preparation tools for GRI 205-2 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members

01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

I mapped the coverage figure to the relevant region(s) used in our reporting pack and checked that the same geographic basis was applied consistently across the underlying counts and the published percentage.The assurer may test whether the region basis was chosen consistently, whether any sites or entities were left out, and whether the published number matches the stated geography.Reporting boundary note; list of included locations/entities; source dataset with region tags; reconciliation between regional extract and published figure; sign-off showing the geography used for the calculation.

I counted only the board-level people to whom the anti-bribery policy pack had actually been shared, using a dated communication log rather than an estimate, and I checked the headcount against the board roster before release.The assurer may probe whether the population was defined correctly, whether the communication evidence is dated and complete, and whether the count excludes duplicates or people outside the intended group.Board roster for the reporting period; communication register or email distribution record; attendance/acknowledgement logs where used; calculation sheet showing inclusions and exclusions; review sign-off.

I derived the board communication percentage from the same board population used for the count, and I checked the numerator and denominator tie back to the source records before publishing.The assurer may test the arithmetic, the denominator basis, and whether the percentage was calculated from the same population as the count.Calculation workbook; source count and total board membership record; formula audit trail; reviewer check of the percentage; version history of the published table.

I grouped employees by the internal staff categories used in our HR system, then checked that the categories in the disclosure matched the source extract and did not double-count anyone.The assurer may question whether the employee categories are internally defined and applied consistently, and whether the grouping could distort the totals or percentages.HR category definitions; employee extract with category fields; reconciliation showing no duplicates; mapping from HR categories to disclosure categories; approval of the category basis.

I counted the employees who had been sent the policy materials using our training and communications records, and I reconciled the total to the employee list for the period before publication.The assurer may probe whether the employee population is complete, whether the communication evidence is reliable, and whether the count includes only those actually reached.Employee population file; training/communications logs; system export showing recipients; reconciliation to HR headcount; evidence of management review.

I calculated the employee communication percentage from the same staff base used for the total, and I checked the formula and rounding before the figure went into the report.The assurer may test the formula, the denominator, and whether rounding or presentation changes the result materially.Calculation sheet; formula check; rounding policy or working note; reviewer sign-off; final published version.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The request goes to the wrong team, so the figures are chased from the board secretary, HR, procurement, and compliance instead of the people who actually hold the communication and training records.

Framework language only

The data call is sent out using disclosure jargon, so business teams cannot map it to their own registers, course logs, or briefing records.

Scope not fixed

No one agrees which board members, staff groups, business partners, or other recipients are in scope, so different teams count different populations.

Period basis drift

One team pulls the latest headcount while another uses year-end records, so the numerator and denominator come from different dates.

Mixed counting method

Some records are counted as people, others as sessions or contacts, which makes the totals and percentages impossible to compare.

Source labels lost

The original file names, system fields, and category tags are stripped away, so the audit trail no longer shows where each figure came from.

Separate groups merged

Board members, employees, business partners, and other recipients are rolled into one total, which hides the split needed for the disclosure.

Evidence details missing

The team keeps the numbers but not the supporting metadata, such as who issued the record, when it was created, and which population it covers.

No sign-off trail

The draft figures move forward without a named reviewer and approval record, so nobody can show who checked the source data before reporting.

Where judgement is often needed

Set the reporting boundary after mergers, sales, and restructures

Use the headcount and partner list that match the reporting period you are describing, and explain any step-change caused by buying, selling, or moving parts of the business in or out of scope.

Choose one rule for who counts as a worker or partner

Where local labels differ, map each population to a single internal category for the report and state that basis so the same people are not counted differently across countries or teams.

Decide how to treat people just inside or just outside the scope

Make a clear call on borderline cases such as temporary staff, contractors, secondees, agents, and other connected parties, then disclose the rule used to include or exclude them.

Fix the timing point for both communication and training counts

State whether the figures reflect the position at period end, the average over the period, or another cut-off, and keep the numerator and denominator on the same basis.

Separate one-off communication from completed training

Count a person as informed or trained only when your own evidence shows the relevant message or session reached them, and explain if you rely on attendance logs, acknowledgements, or another record.

Handle partial coverage and mixed delivery methods consistently

If some groups received the message through induction, e-learning, live sessions, or local briefings, describe the method used and how you avoided double counting the same person or organisation.

Use estimates only where records are incomplete

If you cannot measure every person or partner directly, disclose that the figure is estimated, explain the method and any assumptions, and keep the estimate separate from counted records where possible.

Round percentages and totals in a way that still reconciles

Apply one rounding rule across the disclosure, and if rounded percentages do not exactly match the totals, note the reason so readers can follow the arithmetic.

Protect personal data when reporting small groups

Where a small team or country group could identify individuals, aggregate the figures to a safer level and explain the grouping approach without exposing personal information.

Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Retail distribution

Synthetic example: we set out who has been briefed on our anti-bribery and corruption rules, and who has had formal training, across the board, staff groups, and selected trading partners. The figures below are illustrative only and internally consistent.

Use this as a pattern for showing both communication coverage and training coverage, split by audience and region where relevant.

Illustrative (synthetic) example — Construction services

Synthetic example: we report, in plain terms, how widely our anti-corruption rules were shared and how many people completed training, using a regional split for staff and a separate view for external counterparties. The numbers are made up for illustration and add up consistently.

Use this as a pattern for a second reporter with a different sector and a different mix of audiences, while keeping the arithmetic internally consistent.

Company reports

How companies report GRI 205-2

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

CAE Inc.

Aerospace and Defense · Canada · 2024

Open report →

CAE Inc.’s FY24 Global Annual Activity and Sustainability Report provides numeric data on anti-corruption policy communication, stating that 12,811 to 13,217 employees have been reached (p.165), and mentions training hours provided to employees, totaling 11,997 hours (p.177). The report also references anti-corruption programs aligned with relevant laws (p.185) and includes some context on training related to the Code of Business Conduct (p.130) and data-driven learning insights (p.88). However, the report lacks clear percentage values or detailed narrative explanations regarding the effectiveness or scope of these anti-corruption measures, and no quotable methodology or comprehensive narrative was found.

ITP Aero Group

Aerospace and Defense · Spain · 2024

Open report →

ITP Aero Group’s 2024 ESG Report includes some numeric references to anti-corruption measures and training, notably on pages 152 and 120, where it mentions management approaches, policy commitments, communication, and training related to anti-corruption (p.152), as well as commemorating Anti-Corruption Day and promoting law enforcement agencies (p.120). The report also references governance and ethics compliance topics around pages 116 and 118. However, no clear narrative explanations or percentage values related to anti-corruption efforts were found, and the methodology or detailed descriptions remain unclear.

Compal Electronics, Inc.

Technology Hardware and Equipment · Taiwan · 2025

Open report →

Compal Electronics, Inc.'s 2025 ESG Report includes a reference to anti-corruption policies and procedures along with relevant ethical management guidelines and mentions regular annual risk assessments on page 70. The report also contains sections on governance, business performance, taxation, corporate governance, risk management, and compliance, as indicated on pages 58, 59, 60, and 74, with governance structure details on page 208. However, the report lacks specific numeric or percentage values and detailed narrative explanations related to the disclosure, with many datapoints not found or unclear.

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Scenarios to work through

A group of 12 board members approved the anti-bribery policy in March, but only 9 attended the briefing and 3 joined later by email. The training log also shows that 2 of the 12 have not yet completed the anti-corruption workshop.

QHow should you decide what to count for board communication and board training, and what should you do with the percentages?

Reveal model answer →

A sales team of 40 employees received an anti-corruption e-learning module, but 5 new starters joined after the annual rollout and have not yet been assigned the course. The HR report also includes 8 contractors in the same system, although they are not employees.

QWhich people should be included in the employee figures, and how should you avoid overstating the coverage?

Reveal model answer →

A procurement team sent the anti-corruption policy to 18 strategic suppliers and 6 logistics agents, but the draft report only says 'business partners' without naming the type. The evidence pack shows that all 24 received the policy, yet the narrative does not explain how the message was delivered to a small group of consultants who were not in the main supplier list.

QWhat should you record for partner communication, and what extra detail is needed for the consultants?

Reveal model answer →

The company ran a short anti-corruption refresher for 7 of 9 directors and 62 of 80 employees during the year. The reporting team is tempted to combine the two training sessions into one total because the same slide deck was used.

QShould the board and employee training figures be merged, and how should the percentages be presented?

Reveal model answer →

Framework references