Incidents of non-compliance concerning marketing communications

Zydus Lifesciences Limited provides a clear zero-incidents figure for GRI 417-3.

The Ethical Marketing Performance table on page 135 reports zero incidents of non-compliance concerning marketing communications for FY 2024–25 and each of the three preceding periods.

Because GRI 417-3 permits a brief statement where no non-compliance with regulations or voluntary codes has been identified, the zero figure can satisfy the disclosure if it covers both sources of non-compliance.

The current card should:

cite the marketing-communications row on page 135 rather than the separate product-information and labeling row;

remove materiality and risk-management information from page 148;

remove the suggestion that unspecified narrative elements are missing;

verify whether the zero figure covers regulations and voluntary codes; and

classify the disclosure as substantially aligned with the zero-incidents route.

The current card cites the wrong row, although the same report separately provides a zero figure specifically for marketing communications.

Firstsource Solutions Limited’s GRI Content Index provides a zero-incidents statement for GRI 417-3.

The index states that no incidents of non-compliance with marketing-communication regulations or voluntary codes were reported during the reporting period.

It also describes the disclosure as “not applicable” because Firstsource operates business-to-business and follows ethical communication guidelines. That rationale should be treated cautiously: a business-to-business model does not by itself make marketing communications or GRI 417-3 inapplicable.

The current card should:

remove all references to forced or compulsory labor and GRI 409-1;

remove occupational health and safety data;

cite the GRI Content Index location containing the zero statement;

recognise that the statement expressly covers regulations and voluntary codes;

note that “not applicable” is not supported solely by the business-to-business nature of the company; and

classify the zero statement as relevant GRI 417-3 evidence.

Firstsource’s report expressly maps GRI 417-3 and states that no non-compliance with marketing-communication regulations or voluntary codes was reported.

Owens Corning’s 2024 Sustainability Report provides a relevant but qualified zero-incidents statement on page 184.

The Product Transparency section states that the company had no material incidents of non-compliance with regulations or voluntary codes concerning labeling, marketing or advertising of its products and material services.

The statement has two limitations for GRI 417-3:

it combines labeling with marketing and advertising, spanning both GRI 417-2 and GRI 417-3; and

it is restricted to “material” incidents, while GRI 417-3 does not prescribe a materiality threshold.

The current card should:

remove parental-leave data;

remove employee health-screening information;

remove assurance-provider independence information;

use page 184 as the principal evidence;

identify the combined labeling/marketing scope;

identify the unsupported materiality qualifier; and

classify the disclosure as partial rather than complete.

Owens Corning’s actual relevant disclosure appears on page 184 and combines labeling, marketing and advertising under a “no material incidents” statement.