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GRI 202: Market Presence 2016 · Topic Standard · Cross-sectoral
Disclosure GRI 202-1

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

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.

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

This disclosure asks an organisation to explain how the pay for people starting in standard entry-level roles compares with the local minimum wage, and to do so separately for women and men where relevant. The point is to show whether entry pay sits above, at, or below the legal floor in the places where the organisation operates, rather than to describe pay policy in general terms.

In practice, the focus is on the scope of coverage and the basis of comparison. An organisation should be clear about which operations, countries, sites or employee groups are included, and whether the figures reflect the whole workforce or only selected locations such as flagship sites. If pay differs across locations, the reporting should make that visible so readers can understand the extent of coverage and any variation in entry-level pay relative to local minimum wage.

* 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.

Preparation
Key datapoints to prepare
DatapointWhat to captureEvidence hintOwner
Key operating sitesList the sites that matter for this disclosure, using the organisation’s own threshold for what counts as significant and keeping the list aligned to the reporting period.Site register, legal entity map, country/region operating list, and any internal note showing how significance was assessed.Operations / Finance
Gender splitCapture the gender categories used for the reported population and the counts or shares attached to each category, using the same classification as the source workforce data.HRIS workforce extract, payroll headcount report, and the organisation’s gender classification guidance or employee self-identification fields.HR / People Analytics
Minimum-wage coverageState whether a material share of employees are paid using rates that sit under minimum-wage rules, based on the employee population in scope for the period.Payroll rates file, wage compliance review, and the employee population extract used for the calculation.Payroll / HR
Entry pay ratioCalculate the starting pay rate against the relevant minimum pay rate and express the result as a percentage, using the same pay basis for both figures.Pay scale or offer-rate schedule, minimum wage reference table, and the calculation workbook showing the numerator and denominator used.Compensation / Payroll
Non-employee coverageIndicate whether a material share of non-employees who help deliver the organisation’s work are paid on rates covered by minimum-wage rules, using the same scope definition throughout.Contractor, agency and outsourced labour records; supplier or labour-provider rate schedules; and the scope note for the worker population.Procurement / HR / Operations
Minimum-pay check methodDescribe the checks used to confirm that the relevant non-employee group is paid above the minimum level, including the data sources, test steps and any exceptions found.Compliance review memo, payroll or invoice testing, contract rate checks, and exception log.Payroll / Procurement / Compliance
Local wage gap by sexFor each significant site, note whether a local minimum wage is missing or changes by gender, and record the position separately for each gender category used.Country wage law summary, local HR policy note, and site-by-site legal review showing whether a single rate or gender-based rates apply.Legal / HR / Country management
Reference wage chosenName the wage benchmark selected where more than one minimum can be used, and explain which reference was applied for the calculation or comparison.Policy note, legal interpretation memo, and the calculation file showing the chosen benchmark and why it was used.Legal / Payroll / Compensation
Site significance ruleSet out the rule used to decide which operating sites are treated as significant, including the threshold, basis of assessment and any exclusions.Disclosure methodology note, internal materiality rule, and the site list reviewed against that rule.Finance / Reporting
Show GRI 202-1 sub-elements (LRA working checklist)
  • Check whether a meaningful share of employees are paid on rates tied to minimum-wage rules.
  • Check whether a meaningful share of non-employee workers doing the organisation’s work are paid on rates tied to minimum-wage rules.
  • Set out how you define the locations that count as important operating sites.
  • Describe the steps used to test whether those workers are paid above the minimum rate.
  • State the gender category used for the analysis.
  • At important operating sites, note where no local minimum rate exists or where it varies, broken down by gender.
  • Show the ratio between the starting wage and the minimum wage.
  • List the important operating sites covered.
  • Identify which minimum wage benchmark you have used where more than one could apply.

LRA working checklist - paraphrased; see official source

How to prepare
  1. Set the reporting boundary first. List the sites you will treat as material for this disclosure, and write down your own working definition of what makes a location material so the reader can see how the boundary was chosen.
  2. Decide which pay groups are in scope. Check whether a material share of employees is paid under wage rates linked to minimum-pay rules, and separately check the same point for other workers who help deliver the organisation’s activities but are not employees.
  3. Gather the source records before drafting. Pull together payroll, contract, location, and policy evidence that supports the yes/no answers, the wage comparison, and any explanation of how you tested whether pay sits above the floor.
  4. Prepare the figures and narrative in the required format. Where a ratio is needed, calculate the entry-level pay compared with the relevant minimum and present it as a percentage; where a narrative is needed, explain the approach used to assess non-employee workers and the minimum-pay reference chosen when more than one could apply.
  5. Record any special conditions clearly. If a local minimum rate is missing or differs across a material site, note that situation and state which benchmark you used, including the gender basis where relevant.
  6. Review the draft against the source data and the official guidance. Confirm that the scope, definitions, evidence trail, exclusions, and any changes from prior reporting are all consistent, complete, and traceable before sign-off.
Want to do this on a real report? Practise GRI social disclosures live with Dr. Kurinko — GRI Standards Certified Training. Explore →
Request entry pay and minimum-wage comparison data

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

For our significant sites, what is the starting pay level by gender compared with the local minimum wage, and what checks were done where the local benchmark is unclear or varies?

Use your organisation’s own pay and workforce terms first, then map them to the disclosure fields. For example, use your internal labels for sites, worker groups, starter pay, and local wage benchmark rather than framework wording. This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.

Weak request

Please provide the GRI 202-1 data for significant locations of operation, gender, minimum wage references, and the ratio of entry level wage to minimum wage.

Why it fails: It uses framework language only, does not tell the owner what internal records to pull, and leaves out the practical details needed to build the comparison: which sites, which pay basis, which source system, how gender is grouped, and how to handle cases where the local benchmark is not straightforward.
Better request

Please pull the starter-pay review for our key sites for [period]: list the sites covered, the starter pay rate by gender, the local wage benchmark used at each site, and any notes where more than one benchmark could apply or where no clear benchmark exists. Also include any checks done for non-employee workers tied to our activities and a short note on how your team defines the key sites.

Formal email template
Subject: Data request – starter pay and local wage comparison for [reporting period]

Hi [name/team],

We are preparing a sustainability reporting pack and need your help with a pay and wage comparison for our key sites.

Please send:
- the list of significant sites you used for the review;
- starter pay by gender for those sites;
- the local wage benchmark used at each site, including any cases where more than one benchmark could apply;
- whether any sites have no clear local benchmark or more than one possible benchmark, and how that was handled;
- whether any non-employee worker groups tied to our activities were checked, and what was done to confirm they are above the local wage floor;
- a short note explaining how you define the key sites in your team’s process.

Please return the data in a table and include the source system, date extracted, and any assumptions or exceptions.

This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — could you share the starter pay vs local wage data for our key sites for [period], split by gender, plus any notes on sites where the local benchmark is unclear or varies? Please include the source, assumptions, and how you define the key sites. Thanks.
Industry examples
Retail

Context. Store network with many small sites and a mix of hourly and salaried starters

Adapted request. Please share the starter hourly rate by gender for our main stores and distribution sites in [period], plus the local wage floor used at each site. If a store sits in a place with more than one wage benchmark, note which one you used and why. Also confirm whether any agency or concession staff linked to store operations were checked.

Example response. A table listing each store or depot, country, gender split, starter hourly rate, local wage benchmark, benchmark type, ratio, and a note for any site with more than one possible benchmark.

Hospitality

Context. Hotels and restaurants with tipped and non-tipped starter roles across several cities

Adapted request. Please provide the entry pay review for our hotels and restaurants in [period], split by gender, showing the starter pay used for each site and the local wage benchmark applied. Where city, regional, or age-based wage floors could apply, note which one was selected. Include any review of outsourced or casual staff supporting our operations.

Example response. A site-by-site table with hotel or restaurant name, role family, gender, starter pay basis, local wage benchmark, comparison result, and a short note on benchmark selection and any casual worker checks.

The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.

Draft your disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Explain how you identified the sites treated as major operating locations, which wage benchmark you used where several could apply, and how you checked whether employees and other workers involved in the organisation’s activities were paid above the relevant minimum.

Context note

Set out what the figures mean in practice: they show where minimum-wage rules apply, how entry pay compares with the chosen benchmark, and whether the organisation has any sites where the local minimum is missing or differs by gender.

Fluctuation statement

If the figures changed from the prior period, note whether this was driven by changes in the sites included, the wage benchmark selected, the mix of worker groups covered, or movements in local minimum rates.

Content index entry

GRI 202-1 Ratios of standard entry level wage by gender compared to local minimum wage — [location / page] / [notes]

Assurance readiness
For each claim, check the evidence
ClaimRiskEvidence to check
We built the coverage figure from the sites we treat as material to the business, using a documented cut-off and a named reviewer for the final list.The assurer may question whether the site selection was consistent, complete and free from hindsight bias, and whether the final population matches the basis used in the report.['Documented site-selection method and materiality rationale', 'Final site list with approval trail', 'Management sign-off showing the reporting cut-off date', 'Reconciliation between the site list and the disclosed coverage figure']
We split the workforce data by women and men using the same source records we used for payroll reporting, and we checked the totals before publication.The assurer may probe whether the gender split was based on reliable source data, whether categories were applied consistently, and whether the published totals reconcile to underlying records.['HR or payroll extracts used for the calculation', 'Data dictionary or coding rules for the gender split', 'Reconciliation of gender totals to headcount totals', 'Evidence of review and sign-off before release']
We only included employees whose pay is set against a wage floor, and we kept a working paper showing how we identified that group.The assurer may challenge whether the population was defined correctly, whether exclusions were justified, and whether the method was applied consistently across the group.['Population definition and inclusion/exclusion rules', 'Employee listing or sample used to identify the group', 'Working paper showing the screening process', 'Review notes or approval of the final population']
We calculated the entry pay comparison from the approved wage rates in force at the reporting date and checked the arithmetic before the figure went out.The assurer may test whether the right wage rates were used, whether the comparison basis was consistent, and whether the calculation was accurate.['Approved wage rate schedules and effective dates', 'Calculation sheet showing the comparison basis', 'Evidence of arithmetic checks or independent review', 'Version-controlled final figure used in the report']
For non-employee labour, we mapped the relevant worker groups, tested how their pay was set, and kept evidence for the groups we included and excluded.The assurer may ask whether the non-employee population was complete, whether the pay basis was assessed properly, and whether any exclusions were reasonable.['List of non-employee worker groups in scope', 'Contracts, invoices or labour supplier records', 'Method note explaining how pay basis was assessed', 'Evidence of review of included and excluded groups']
We documented the checks we carried out to see whether those workers were above the wage floor, including the source records and any follow-up queries.The assurer may probe whether the testing was sufficient, whether source records were trustworthy, and whether unresolved exceptions were handled appropriately.['Testing plan or procedure for the wage-floor check', 'Source records used in the review', 'Exception log and follow-up correspondence', 'Sign-off showing completion of the checks']
Evidence pack to prepare
  • The governing policy or written commitment behind this disclosure
  • A methodology / definition note setting out how the disclosure was scoped and prepared
  • Source-system exports the figures or facts were drawn from
  • The internal approval / sign-off record for the disclosure before publication
  • Minutes 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.
Examples
Illustrative examples

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

Food manufacturing · synthetic · written by LRA
Illustrative pay-floor comparison at major operating sites (people / %)
CategoryWomenMenTotal
UK site: employees paid from local floor120180300
UK site: entry starting rate as % of local floor100100200
Poland site: employees paid from local floor80120200
Poland site: entry starting rate as % of local floor100100200
Other workers checked against floor4555100
Other workers found above floor4555100

We use our own working definition of major operating sites: locations that account for at least 10% of group headcount or 10% of payroll. In this synthetic example, our UK and Poland sites are the only major locations; both have a local floor for pay, and we show the entry starting rate against that floor by gender, plus the checks we used for contractors and agency staff.

Synthetic illustration only. Shows how to describe major sites, the pay-floor basis used, whether a local floor exists or varies by gender, the entry-rate comparison, and the checks used for non-employee workers.
Logistics and warehousing · synthetic · written by LRA
Illustrative pay-floor comparison at major operating sites (people / %)
CategoryWomenMenTotal
Germany site: employees paid from local floor150150300
Germany site: entry starting rate as % of local floor100100200
Spain site: employees paid from national floor90110200
Spain site: entry starting rate as % of local floor100100200
Other workers checked against floor6040100
Other workers found above floor6040100

For this synthetic disclosure, we treat a site as major when it has at least 8% of group staff or 8% of group labour spend. Our main sites are in Germany and Spain; Germany has one local pay floor for all workers, while Spain has no local floor, so we use the statutory national floor there and explain the review steps for agency and subcontracted labour.

Synthetic illustration only. Shows a different way to define major sites, how to state the reference pay floor used where more than one could apply, how to note absence of a local floor, and how to explain checks on non-employee workers.
Draft output & visualisation ideas

How to turn the collected data into a draft disclosure. The charts below are drawn from the illustrative figures above — swap in your own data.

Food manufacturing — Illustrative pay-floor comparison at major operating sites
Illustrative pay-floor comparison at major operating sites (people / %)0250500Women: 120Men: 180300UK site: employees pa…Women: 100Men: 100200UK site: entry starti…Women: 80Men: 120200Poland site: employee…Women: 100Men: 100200Poland site: entry st…Women: 45Men: 55100Other workers checked…Women: 45Men: 55100Other workers found a…WomenMen
Logistics and warehousing — Illustrative pay-floor comparison at major operating sites
Illustrative pay-floor comparison at major operating sites (people / %)0250500Women: 150Men: 150300Germany site: employe…Women: 100Men: 100200Germany site: entry s…Women: 90Men: 110200Spain site: employees…Women: 100Men: 100200Spain site: entry sta…Women: 60Men: 40100Other workers checked…Women: 60Men: 40100Other workers found a…WomenMen

Other views you could build

  • Where the workforce sits and how pay rules vary — map: A location-by-location view of the places that count as major operating sites, with an indication of where pay is tied to minimum-wage rules and where local minimums are missing or change by gender.
  • Entry pay compared with the relevant minimum — bar: A comparison of the starting wage level against the minimum benchmark used at each major operating site, so readers can see the gap or margin.
  • Coverage of minimum-wage-based pay across worker groups — stacked bar: The share of employees and the share of other people doing work for the organisation who are paid using minimum-wage-linked rates, split to show which groups are covered and which are not.
  • How the minimum benchmark is chosen — table: The reference point used where more than one minimum rate could apply, alongside the definition applied to decide which sites are treated as major operating locations.
  • Pay-rule status by gender at sites without a fixed local minimum — stacked bar: A gender split for major operating sites where the local minimum is absent or changes, showing how pay arrangements are assessed in those cases.
  • Overall minimum-wage coverage across worker categories — donut: A simple proportion of the organisation’s workforce-related groups that are paid under minimum-wage rules versus those that are not, based on the collected data.
From a number to a disclosure

What separates a figure from a disclosure.

Basic

I report a 112% starting-pay-to-minimum-pay ratio for women and 108% for men.

Better

I report that, across our main sites, women’s starting pay is 112% of the local floor and men’s is 108%, using the minimum rate we selected where more than one benchmark applies.

Best

I report that, for the year ended 31 December 2025 across our significant sites, women’s starting pay was 112% of the local floor and men’s was 108%; we used the lowest applicable local benchmark where several existed, and the small gap reflects different starting grades in two locations.

From company reports
Real published reports Compare side by side →Get it free

Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 202-1 — these are report practice, not exact disclosure examples.

CompanySector · CountryYearMatchPageReportAssurance
Sumitomo Forestry Co., Ltd. Home Building · Japan 2025 Exact p. 530 →p. 455 →p. 50 → Sustainability Report 2025 → EY; BSI
Evidence in Sumitomo Forestry Co., Ltd.’s report

What the report shows

Sumitomo Forestry Co., Ltd.'s Sustainability Report 2025 provides several covered datapoints related to labor practices and diversity, including a reported significant risk for incidents of forced or compulsory labor (p.536) and data on the ratio of female employees to all employees both in the non-consolidated entity and subsidiaries in Japan, with percentages around 24-37% (pp.56, 61). The report also includes information on entry-level wages by gender compared to local minimum wage and proportions of senior management hired, indicating some gender-related wage and employment data (p.530). However, there is no clear headline value or detailed narrative on incidents of discrimination or corrective actions beyond brief mentions, and some contextual information on employee awareness and management actions is partial without specific figures (p.303).

Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict.

Datapoint coverage

DatapointStatusPage
Key operating sitesA reported value was found on this page. covered p. 536
Gender splitA reported value was found on this page. covered p. 535
Minimum-wage coverageA reported value was found on this page (%). covered p. 61
Entry pay ratioA reported value was found on this page. covered p. 530
Non-employee coverageA reported value was found on this page (%). covered p. 524
Minimum-pay check methodSupporting context was found, but no headline value. partial p. 303
Local wage gap by sexA reported value was found on this page. covered p. 530
Reference wage chosenNo quotable evidence was found in this report. not found
Site significance ruleA reported value was found on this page (%). covered p. 56

Source trail

  • p. 536significant risk for incidents of forced  or compulsory labor 4.8 6.3.1 6.3.2 6.3.3 6.3.4 6.3.5 6.3.10 6.6.6 Security
  • p. 536Disclosures ISO26000 Disclosure Location Forced or Compulsory Labor 2016 409-1 Operations and suppliers at significant risk for incidents of forced  or compulsory labor 4.8 6.3.1 6.3.2 6.3.3 6.3.4 6.3.5 6.3.10 6.6.6 Security Practices 2016 410-1 Security personnel trained in human rights policies or procedures 4.8…
  • p. 448r) An executive of a corporate entity that the Company or its subsidiary owns at least 10% of their total voting rights. 5.Transaction parties (ⅰ)Customers (major transaction parties): An individual (or in the case of a corporate entity, an executive of that entity) to whom our sales amount to that individual or…
  • p. 4497.Contribution recipients An individual (or in the case of a corporate entity, an executive of that entity) that the Company or its subsidiary has contributed an average 10 million yen a year or 2% of total income, whichever is higher, over the past three fiscal years. 8.Family A spouse or relative within the second…
  • p. 325Trend in health checkup results* FY2021 FY2022 FY2023 FY2024 Health checkup results (%) 2.5 3.0 2.3 2.6 Trend in smoking rate FY2021 FY2022 FY2023 FY2024 Smoking rate (%) 22.0 21.3 21.5 20.9 Trend in regular exercise rate* FY2021 FY2022 FY2023 FY2024 Regular exercise rate (%) - - 61.1 61.8 Initiatives to Maintain and…
  • p. 535women to men 6.3.7 6.3.10 6.4.1 6.4.2 6.4.3 6.4.4 Non-discrimination 2016 406-1 Incidents of discrimination and corrective actions
  • p. 440gender)* Male Female Number (persons) 8 2 Ratio(%) 80 20 Governance Basic Policy Click here for related information Integrated Report
  • p. 522Male and Female Employees (%) FY2024 All employees Regular employees Part-time and fixed-time employees 49.4 65.9 60.4 Average Annual
  • p. 326e this program for all employees in order to raise awareness of health. The participation rate in fiscal 2024 was 91.1%. Furthermore, to help address women's health issues, we held an online training called "Men Should Hear This Too! A Seminar on Women's Health for All" in November 2024. It featured an invited…
  • p. 61female employees to all employees (%) Non-Consolidated Personnel Department 24.4 25.1 26.0 26.8 Subsidiary Companies in Japan 35.2 36.0 37.0 37.1 Female
  • p. 329k Program Based on the Industrial Safety and Health Act" (the ratio of high-stress employees is about 10% of the total). * Human Rights - Diversity, Equity and Inclusion - Human Resources Development - Work-Life Balance - Occupational Health and Safety -  Safety and Quality of Products and Services - Communication…
  • p. 387d 60 out of 223 entries and awarded the "Your Kirari Award" to 24 people based on comments submitted by Group employees. Respect for and Application of Customer Feedback Human Rights - Diversity, Equity and Inclusion - Human Resources Development - Work-Life Balance - Occupational Health and Safety -  Safety and…
  • p. 530entry level wage by gender compared to local  minimum wage 6.3.7 6.3.10 6.4.3 6.4.4 6.8.1 6.8.2 ‒ 202-2 Proportion
  • p. 524Women (Non-Consolidated) FY2021 FY2022 FY2023 FY2024 Female employees including contract employees*1 (%) 22.6 23.1 23.8 24.4 Ratio of females
  • p. 524and development / technical positions*1*3 (%) - - 24.8 20.6 Diversity Calculated based on enrollment as of December 31. The number of employees includes people dispatched to affiliate companies but excludes executive officers, employees hosted from other companies and exchange employees *1 Calculated by adding the…
  • p. 54Impact on Society and the Environment Material Issue 6 Impact (Opportunities) Impact (Risks) To create a vibrant environment for all workers Creating a work environment where everyone throughout the supply chain is safe, healthy and motivated. In Mid-Term Sustainability Targets 2024, Material Issue 6 is divided into…
  • p. 530gender compared to local  minimum wage 6.3.7 6.3.10 6.4.3 6.4.4 6.8.1 6.8.2 ‒ 202-2 Proportion of senior management hired from
  • p. 56female employees to all employees (%) Non-Consolidated 24.5 24.4 △ 25.1 Subsidiary Companies in Japan 34.7 35.2 〇 36.0 Female officer
  • p. 351medical specialists is promoted more than before, and safety of customers and the safety of staff members are achieved. Occupational Injuries (Non-Consolidated)*1 FY2021 FY2022 FY2023 FY2024 Number of occupational injuries (incidents)*1 2 5 4 3 Lost-time injury frequency rate*2 0.19 0.42 0.47 0.31 Work-related…
  • p. 303From these results, we provide feedback to help each employee precisely recognize the current situation (awareness), gain hints into specific management actions as well as help them formulate and execute independent action plans. In addition, these evaluation results also provide feedback to supervisors and senior…
Sims Limited Solid Waste Management Utilities · Australia 2025 Exact p. 64 →p. 67 →p. 5 → Sims Sustainability Report FY25 → ey
Evidence in Sims Limited’s report

What the report shows

Sims Limited’s 2025 Sustainability Report provides several covered datapoints related to social standards, including a noted significant risk for incidents of child labor (p.67) and gender-related workforce data such as women to men ratios and senior management hiring proportions (pp.64, 67). The report also discusses employee consultation during significant operational changes (p.66) and references detailed workforce diversity and development data (p.62). However, some narrative elements remain unclear or not found, with no quotable evidence for certain aspects and missing methodology or narrative details for disclosure part (d).

Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict.

Datapoint coverage

DatapointStatusPage
Key operating sitesA reported value was found on this page. covered p. 67
Gender splitA reported value was found on this page. covered p. 67
Minimum-wage coverageSupporting context was found, but no headline value. partial p. 66
Entry pay ratioA reported value was found on this page. covered p. 64
Non-employee coverageA reported value was found on this page. covered p. 62
Minimum-pay check methodNo quotable evidence was found in this report. not found
Local wage gap by sexNo quotable evidence was found in this report. not found
Reference wage chosenNo quotable evidence was found in this report. not found
Site significance ruleNo quotable evidence was found (methodology/narrative). unclear

Source trail

  • p. 67significant risk for incidents of child labor 2024 Modern Slavery Statement Forced or Compulsory Labor 2016 409-1 Operations
  • p. 68relates to landfills and waste-to-energy facilities only, which are facility types that Sims Limited does not operate. 96% of Sims Limited facilities (metal shredders, intake yards and circular electronic centres) are in or near areas of dense population as they are located near communities that generate end of…
  • p. 67GRI 400 Series: Social Standards Topic disclosures Disclosure title Sims Limited response Training and Education 2016 404-1 Average hours of training per year per employee FY25 Sustainability Data Book – Workforce Development tab 404-2 Programs for upgrading employee skills and transition assistance programs FY25…
  • p. 58Metrics and Targets M E T R I C S A N D TA RG E TS All our metrics can be found in our Databook. Metrics disclosed include: Climate ■ Total energy consumption ■ Direct sources (Scope 1) ■ Fugitive emissions including refrigerants ■ Indirect sources (Scope 2 location-based and market-based) ■ Scope 1 and…
  • p. 67women to men FY25 Sustainability Data Book – Workforce Development tab Freedom of Association and Collective Bargaining 2016 407-1 Operations
  • p. 58Gender pay gap ■ Health and safety data ■ Workforce development ■ Workforce and diversity ■ Community and economic 56 Sims Limited Sustainability Report
  • p. 25women is 9% compared to 12% for men. The most common reasons cited in exit surveys included career opportunities and flexible
  • p. 64gender, but we pay above minimum wage in all areas we operate in. 202-2 Proportion of senior management hired
  • p. 62General 2-6 Activities, value chain and other business relationships FY25 Annual report – how we create value General 2-7 Employees FY25 Sustainability Data Book – Workforce Diversity tab General 2-8 Workers who are not employees FY25 Sustainbaility Data Book – Workforce & Diversity tab. Sims measures the Total…
  • p. 8significant non-recurring items, the impact of non-qualifying hedges and internal recharges DATA CENTRE DECOMMISSIONING + REPURPOSING METAL
  • p. 5gender pay gap ■ health and safety data. The assurance statement, provided by Apex, offers limited assurance over the selected ESG data
  • p. 66significant operational changes, we provide timely disclosure and consult with employees in accordance with mechanisms under relevant industrial
  • p. 4gender pay equity, and other workforce indicators. The FY25 Sustainability Report outlines Sims Limited’s performance and progress across key environmental
KGI Financial Holding Co., Ltd. Banks / Diverse Financials / Insurance · Taiwan 2024 Partial p. 128 →p. 93 →p. 82 → 2024 ESG Report → Deloitte
Evidence in KGI Financial Holding Co., Ltd.’s report

What the report shows

KGI Financial Holding Co., Ltd.’s 2024 ESG Report provides detailed data on workforce composition, including gender distribution with 1,085 employees aged 30-49 and a total of 1,980 employees split 44% male and 56% female (pp.82-83). The report also covers operational scale with 305 total operation locations across major subsidiaries (p.6) and includes information on absenteeism numbers by gender (p.101). However, the report lacks clear narrative or methodological explanation regarding some human rights commitments and local hiring practices, with no quotable evidence found for these aspects in the provided pages.

Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict.

Datapoint coverage

DatapointStatusPage
Key operating sitesA reported value was found on this page. covered p. 6
Gender splitA reported value was found on this page. covered p. 82
Minimum-wage coverageA reported value was found on this page. covered p. 128
Entry pay ratioA reported value was found on this page (%). covered p. 93
Non-employee coverageNo quotable evidence was found in this report. not found
Minimum-pay check methodNo quotable evidence was found in this report. not found
Local wage gap by sexA reported value was found on this page. covered p. 101
Reference wage chosenNo quotable evidence was found in this report. not found
Site significance ruleNo quotable evidence was found (methodology/narrative). unclear

Source trail

  • p. 6Operation Locations Major Subsidiaries KGI Life KGI Bank KGI Securities KGI SITE CDIB Total Operation Locations 151 55 91 1 7 305 Main
  • p. 83locations where we operate. The Policy encompasses six major human rights commitments: no discrimination, no bullying, no harassment; no forced
  • p. 63or- mation, establish a data dictionary, develop data lineage, and implement a comprehensive data monitoring mechanism. (Continue) 063 / 138 Preface 1  Sustainability Strategy 2  Corporate Governance 3  Intelligent Finance 4  Talent Development 5  Low Carbon Economy 6  Co-Creation of Sustainable Society 7  Appendix…
  • p. 31significant penalties imposed on the Group by competent authorities. (4) Profitability - The Company's profitability is measured by the budget
  • p. 82Male 495 2 497 46 11.3 Female 585 3 588 54 Sub. Total 1,080 5 1,085 100 30 ~ 49 Male
  • p. 83Gender Male 463 46 402 42 865 44 Female 551 54 564 58 1,115 56 Total 1,014 100 966 100 1,980 100 % to Employees
  • p. 81Male 9,319 37 100 Female 15,944 63 Total 25,263 100 Note: The above includes employees and non-employees
  • p. 83female employees compared to male employees, demonstrating a tangible commitment to gender equality. Internal Transfer Promotion Total No. of People
  • p. 81Male 3,894 40 38.7 Female 5,871 60 Sub. Total 9,765 100 Part-Time Male 1,269 32 15.7 Female
  • p. 128minimum wage 4.4.1 Competitive Compensation 092 202-2 Proportion of senior management hired from the local community 4.1.1 Diversity
  • p. 93level (%) (Note 1) 115 133 The multiple of entry-level salaries to the minimum wage
  • p. 93Female and Male Female Male Female/Male Comparison Adjustment (%) 3.0 3.0 100 Note: Employees below the executive vice president level are eligible
  • p. 93minimum wage. Only two female employees have a salary that is 1.02 times the minimum wage. ■ Comparison of Annual
  • p. 93Female Male The ratio of average annual regular salary above the market level (%) (Note 1) 115 133 The multiple of entry
  • p. 101Male Female Total No. of Absentees 3,496 3,146 1,010 1,922 2,932 No. of Days Absent
  • p. 84minimum wage. • Review the resumes and information of applicants to ensure they are not underage workers. Upon the arrival
Check your understanding
A preparer is drafting the pay note for two large sites, one in Manchester and one in Leeds. The local wage floor is set by different rules at each site, and the team has separate starting pay rates for women and men in each place.How should the preparer decide whether to present one combined ratio or separate figures, and what needs to be clear about the locations and gender split?
Model answer. Use the sites that meet the organisation’s own threshold for being material to this disclosure, and make that threshold clear in the note. If the wage floor differs by place, show the comparison separately for each relevant site and by gender, rather than blending unlike settings into one figure.
Why this matters. Where pay floors vary across material sites, the comparison needs to be anchored to the relevant location and shown in a way that does not hide differences by gender.
At one warehouse, most staff are on hourly contracts tied to the legal wage floor, but a small group of supervisors are paid above it. The reporting team is unsure whether the warehouse should be treated as a site where the disclosure is relevant.What judgement should the preparer make about whether this site belongs in the analysis?
Model answer. First decide whether the site is material under the organisation’s own approach to significant operations. If it is, then check whether a meaningful share of workers there are paid using a wage floor linked to minimum-pay rules; if so, the site belongs in the disclosure and the entry pay comparison should be reported for it.
Why this matters. The first step is to apply the organisation’s materiality threshold for sites, then test whether minimum-pay rules are relevant to a meaningful share of the workforce there.
A company uses agency staff and contractors at a distribution centre, and many of them help deliver the organisation’s activities. The HR team has employee payroll data, but it is not yet clear how to evidence whether those non-employees are paid above the local wage floor.What should the preparer do before concluding that this group can be left out of the wage-floor check?
Model answer. Do not leave them out just because they are not employees. Assess whether a meaningful share of these other workers are paid under arrangements linked to minimum-pay rules, and document the steps used to test whether their pay sits above the local floor.
Why this matters. The disclosure can extend beyond employees, so the preparer needs a documented check for other workers who help carry out the organisation’s activities.
In one country, there is no single local wage floor at the main site: one region has a statutory minimum, another uses a sector rate, and the site employs both women and men across both areas. The reporting lead is unsure which benchmark to use in the ratio.How should the preparer choose the benchmark and explain the choice?
Model answer. State that the local wage floor is not uniform at that site, then identify which benchmark has been used for the comparison and why that one was selected over the alternatives. The explanation should make it clear how the chosen floor was applied for the relevant gender group at that location.
Why this matters. If more than one wage floor could be used, the report needs to name the benchmark chosen and explain the basis for that choice.
Analyse this disclosure across real reports

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Related framework references

How this disclosure maps across the major reporting frameworks.

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GRI 202-1
within GRI 202: Market Presence 2016
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Questions this page answers
How do I prepare a GRI 202-1 Market Presence disclosure using this page in practice?

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 collect the right inputs, document your method, and turn them into a draft disclosure. ↑ section

What data do I need to collect for GRI 202-1 Market Presence on this page?

The page points you to the specific datapoints to prepare: key operating sites, gender split, minimum-wage coverage, entry pay ratio, non-employee coverage, minimum-pay check method, local wage gap by sex, reference wage chosen, and the site significance rule. Use that list as your data-collection checklist before drafting. ↑ section

How should I decide which sites count as key operating sites for GRI 202-1 Market Presence?

The page includes a site significance rule, so you should use that to decide which locations are in scope. Keep the rule and the resulting site list together in your working papers so the scope is clear and repeatable. ↑ section

What should I document about the minimum-pay check method for GRI 202-1 Market Presence?

The page says to prepare the minimum-pay check method and the reference wage chosen, so both need to be recorded clearly. That gives reviewers enough context to understand how the check was done and what benchmark was used. ↑ section

Who should own the data for GRI 202-1 Market Presence in my organisation?

The page does not assign roles, but it is set up for a sustainability/ESG manager, HR or data owner, and assurance reviewer to use together. In practice, assign ownership for each datapoint and for the method so the evidence pack is complete and traceable. ↑ section

What evidence pack do I need to make GRI 202-1 Market Presence assurance-ready?

The page provides an evidence pack with five items for assurance readiness. Use those items to support the datapoints, the method, and the final disclosure so a reviewer can follow the trail from source data to reported output. ↑ section

What are the six assurance claims I should verify for GRI 202-1 Market Presence?

The page includes six assurance claims to check, each with a claim, risk, and evidence prompt. Use them as a reviewer’s checklist to test whether the disclosure is complete, consistent, and supported by the underlying records. ↑ section

What are the common reporting gaps or mistakes for GRI 202-1 Market Presence?

The page lists common reporting gaps and mistakes so you can spot issues before sign-off. Use that section to check for missing datapoints, unclear scope, weak method notes, or evidence that does not match the draft. ↑ section

How can I use the synthetic example disclosure on this GRI 202-1 Market Presence page?

The page includes synthetic illustrative examples, including a quantitative table, to show how the disclosure can be presented. Treat them as formatting and drafting aids only, and make sure any real figures in your own draft are internally consistent. ↑ section

What can I download to help me draft and assure GRI 202-1 Market Presence?

The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise inputs and checks, and the PDF as a quick reference while drafting or reviewing. ↑ section

How do I turn the GRI 202-1 Market Presence data into a draft disclosure?

The page has a draft-output section with visualisation ideas, narrative starters, and a GRI content-index line. Use those prompts to turn your prepared data and method notes into a clear first draft. ↑ section

More questions this page can help with
  • What should I include in the GRI 202-1 Market Presence working papers before I draft the report?
  • How do I make sure my GRI 202-1 Market Presence scope is consistent across sites and data owners?
  • Which GRI 202-1 Market Presence datapoints are most likely to need HR input?
  • How do I evidence the reference wage chosen for GRI 202-1 Market Presence?
  • What should an assurance reviewer look for in a GRI 202-1 Market Presence evidence pack?
  • How do I use the Prep & Assurance workbook for GRI 202-1 Market Presence?
  • What does the printable Library Card help with on GRI 202-1 Market Presence?
  • How do I avoid common mistakes when reporting GRI 202-1 Market Presence?
  • Can I use the synthetic example table as a template for my GRI 202-1 Market Presence draft?
  • What narrative starters does the GRI 202-1 Market Presence page give me?
  • How do I build a GRI content-index line for GRI 202-1 Market Presence?
  • Where can I find real company reports that disclose this topic?
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Sources, status and disclaimer

This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.