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.
Preparation
Key datapoints to prepare
＋ Show GRI 205-2 sub-elements (LRA working checklist)
Set out how anti-corruption rules and procedures have been shared with other people or organisations.
State the employee group used for the figures.
Show what share of business partners were told about the anti-corruption rules and procedures.
Show what share of employees completed anti-corruption training.
Show what share of employees were informed about the anti-corruption rules and procedures.
Show what share of board or committee members completed anti-corruption training.
Show what share of board or committee members were informed about the anti-corruption rules and procedures.
State the region used for the figures.
Give the total number of business partners informed about the anti-corruption rules and procedures.
Give the total number of employees who completed anti-corruption training.
Give the total number of employees informed about the anti-corruption rules and procedures.
Give the total number of board or committee members who completed anti-corruption training.
Give the total number of board or committee members informed about the anti-corruption rules and procedures.
State the kind of business partner involved.
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.
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
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
Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
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
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
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
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.
✓ LRA AI Assistant · Human-in-the-loop
Ask Study Studio AI assistant about this disclosure
Get a practical answer for your reporting context. Your first answer is free — create a free account to continue the conversation.
TryHow do I prepare GRI 205-2?What data do I need to collect?Where can I see a real-report example?What mistakes should I avoid?
1 free answer
Check your understanding
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 →Hide answer ↑Count only the people who were actually reached by the policy briefing when reporting communication, so the communication total is 12 if all 12 were informed, even if by different channels. For training, count only the 10 who completed the workshop, then calculate the percentage against the full board size of 12; that gives 83.3% if rounded to one decimal place. Keep the communication and training figures separate, and make sure the numerator matches the evidence for each line.
Why this matters · Communication and training are different measures, so each one needs its own headcount and percentage based on the same population base.
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 →Hide answer ↑Use the employee population only, so the 8 contractors should not be mixed into the employee count for this line. If the organisation has 40 employees in scope and 35 completed the module, report 35 employees trained and 87.5% coverage; do not include the 5 new starters as trained unless they actually completed the course. If the disclosure also asks about communication to employees, apply the same employee-only population and keep the communication and training totals distinct.
Why this matters · Only include the population named for the line, and do not let contractor or supplier data inflate employee coverage.
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 →Hide answer ↑State the partner type clearly, such as suppliers, agents, or consultants, and report the total and percentage for each group you are covering. For the 24 partners in the evidence pack, the communication figure is 24 and the coverage is 100% if that is the full in-scope group. For the consultants who sit outside the main partner list, add a short description of the method used to reach them, such as contract onboarding, a code-of-conduct pack, or a briefing call, so the report explains how they were informed.
Why this matters · For external parties, identify the partner category and explain any other audience in plain language rather than leaving the method unclear.
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 →Hide answer ↑Do not merge the two populations, because governance members and employees are reported separately. The board training figure is 7 out of 9, which is 77.8%, and the employee training figure is 62 out of 80, which is 77.5%; each percentage should be shown against its own group. Using the same slide deck does not change the need to keep the counts and percentages separate by audience.
Why this matters · Shared content does not mean shared reporting: each audience needs its own count and percentage.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What data do I need to gather for GRI 205-2 Anti-corruption before I start drafting the disclosure?+−
The page lists the core datapoints to prepare, including the geographic region, who was briefed or trained, the relevant grouping for employees and partners, and the related counts and rates. It is designed to help you collect the right inputs before you turn them into a draft.
How should I decide the scope for GRI 205-2 Anti-corruption on this page?+−
Use the page’s step-by-step preparation section and the datapoint list to define the reporting scope consistently, starting with the geographic region and the groups covered. The page is set up to help you make those choices before you build the disclosure.
Who should own the GRI 205-2 Anti-corruption data collection in practice?+−
The page is aimed at sustainability and ESG managers, HR or data owners, and assurance reviewers, so ownership can sit with whichever team holds the briefing, training, and outreach records. The key is to assign clear responsibility for each datapoint before drafting.
What evidence should I include in an assurance pack for GRI 205-2 Anti-corruption?+−
The page includes an evidence pack with five items and also sets out six assurance claims to verify, each with a claim, risk, and evidence angle. That gives you a practical starting point for assembling support that matches the numbers and narrative you plan to report.
What are the common mistakes to avoid when reporting GRI 205-2 Anti-corruption?+−
The page has a section on common reporting gaps and mistakes, which is meant to help you spot issues before sign-off. Use it to check for missing datapoints, weak scope choices, or unsupported figures.
How do I use the Prep & Assurance workbook for GRI 205-2 Anti-corruption?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to support preparation and assurance readiness. It is there to help you organise the datapoints, evidence, and draft output in one place.
What can I take from the synthetic example disclosure for GRI 205-2 Anti-corruption?+−
The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the datapoints may be turned into a draft. Treat it as a worked example only, and keep any figures internally consistent if you adapt the format.
How do I turn the GRI 205-2 Anti-corruption data into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters, and a GRI content-index line to help you move from data to reporting text. It is meant to speed up drafting while keeping the output tied to the prepared evidence.
Can I reuse my GRI 205-2 Anti-corruption data for ESRS G1 Business Conduct reporting?+−
The page notes ESRS G1 as the closest correspondence, so the same underlying data may be reusable across both outputs. You should still check the specific reporting needs for each framework rather than assuming they are identical.
Where can I find real company examples for GRI 205-2 Anti-corruption?+−
The page includes a 'From company reports' table that links to real published reports and points you to the pages where the topic is disclosed. That can help you see how others present similar information without relying on the synthetic example alone.
More questions this page can help with
GRI 205-2 Anti-corruption datapoints checklist for briefing and training countsHow to calculate board briefing rate and employee briefing rate for GRI 205-2 Anti-corruptionWhat evidence do I need for governance training count and employee training rate in GRI 205-2 Anti-corruptionHow to choose employee grouping and partner type for GRI 205-2 Anti-corruption reportingGRI 205-2 Anti-corruption workbook download how to use it for assurance readinessWhat are the six assurance claims to verify on the GRI 205-2 Anti-corruption pageHow to avoid common reporting gaps in GRI 205-2 Anti-corruption disclosuresGRI 205-2 Anti-corruption example disclosure table how to adapt it to my company dataWhat should go in the evidence pack for GRI 205-2 Anti-corruptionHow to write the draft narrative for GRI 205-2 Anti-corruption using the page startersWhere is the GRI 205-2 Anti-corruption content index line on the pageWhich real company reports are linked for GRI 205-2 Anti-corruption examples
Free · LRA Community
Get your GRI 205-2 tools — free
Your preparation tools are free for LRA Community members and students. Register once (it's free) and your download starts right away — plus the Disclosure Library, templates and the LRA AI-assistant.
✓
You're in — your download is starting
Your file is downloading now. Your Community Cabinet — with the Disclosure Library, templates and the LRA AI-assistant — is ready too.
Open your Cabinet →