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ESRS G1: Business Conduct · 2026-5010-final

Disclosure Requirement G1-3

Targets

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 EFRAG source.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

4datapoints↓ 5claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain the targets it has set for its business conduct and governance-related impacts, risks and opportunities, and how those targets are used to steer performance. In practice, the focus is on being clear about what the target is, what it covers, and how progress is tracked, rather than simply stating that a target exists.

The practical question is whether the target applies across the whole organisation or only to selected parts of it, such as particular countries, business units or flagship sites. It should be possible to understand the scope, the time horizon, and how the organisation knows whether it is on track, so readers can judge how embedded the target is in day-to-day management.

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

Before you start

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

Have you pinned down exactly which parts of the business, activities, or locations this target covers, and which are left out? Is the starting point for the target fixed to one clearly identified year or period, so everyone is using the same reference point? Have you agreed the date or period by which progress will be judged, and is that timing written down in a way you can trace? Can you link the target figure back to a source record, model, or approved internal document without relying on memory or informal notes? Have you checked which internal definitions and measurement rules are being used, so the target is built on the same basis throughout?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Target values Record the numeric goal or end-state the organisation says it is aiming for, including the measure used and the intended level to be reached. Approved target sheet, strategy paper, KPI dashboard, or board paper showing the stated goal and metric. Strategy / sustainability

Target coverage State exactly which part of the business, activity, geography, or portfolio the target applies to, and note any exclusions or partial coverage. Target methodology note, scope statement, or internal memo defining the covered entities, sites, or operations. Strategy / sustainability

Starting point Capture the reference starting figure used to set the target, including the date or period it comes from and the metric definition behind it. Baseline calculation file, prior-period report, or source-system extract used to establish the starting value. Finance / sustainability reporting

Delivery date Record the planned date or period by which the target is meant to be achieved, including any milestone years if the plan uses them. Roadmap, target tracker, or approved plan showing the due year or milestone schedule. Strategy / programme management

＋ Show G1-3 sub-elements (LRA working checklist)

Set the starting point used for comparison. State which parts of the business, value chain, or activities are covered. Give the target figures you are aiming to reach. Specify the period or date by which the target should be met.

How to prepare it

1Set the boundary first: identify which parts of the business, value chain, or other relevant activities the target covers, and make that scope explicit in your draft.

2Define the target itself in business terms: state what outcome is being aimed for, and make clear whether you are reporting a value, a range, or another form of target expression.

3Pin down the starting point: record the baseline used for the target, including the reference point from which progress will be measured.

4Capture the timing: note the period or date by which the target is intended to be reached, and keep the timeline consistent across the disclosure.

5Gather support before finalising: collect the internal records, calculations, approvals, and source materials that back the scope, baseline, target value, and timeline you plan to report.

6Check the final wording against the source material: confirm that exclusions, changes, or assumptions are explained where relevant, and verify that the reported information matches the official ESRS source before sign-off.

Request the data

Request the target register and supporting evidence

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

What targets has the organisation set, what do they cover, what starting point were they measured from, and by when are they meant to be reached?

Use your organisation’s own wording first, then map it to the reporting disclosure. Ask for the target register, board or committee papers, and any source files that show how the target wording, coverage, starting point and end date were agreed. Keep the request in business terms the team already uses, then translate it for reporting review.

Weak request

Please send the ESRS G1 targets, including scope, baseline and timeline.

Why it fails: This uses framework language only, so the owner may not know which internal records to pull. It also does not ask for the approval trail or the organisation’s own wording, which are needed to trace the target back to source documents.

Better request

Please send the current target register and the papers that show how each target was agreed. For each target, include the business wording, what it covers, the starting point used, and the date or milestone it is meant to reach, plus the document link or approval reference.

Formal email template

Subject: Request for target details and supporting documents

Hello [name/team],

We are preparing the sustainability reporting pack and need your help with the organisation’s target information for [reporting period].

Please send the current target register, plus any supporting papers or files that show:
- the target wording in your own business terms
- what parts of the business or activity it covers
- the starting point used for comparison
- the date or milestone by which it is meant to be reached
- where the target was approved or agreed

If there are several targets, please include each one separately and note any internal reference numbers or document links.

A possible LRA training template is attached below for adaptation to your organisation. Please check the official source before sign-off.

Many thanks,
[preparer name]

Short Teams / Slack version

Hi [name] — could you share the target register and any supporting papers for [reporting period]? We need the target wording, what it covers, the starting point, the timing, and where it was agreed. Please use your team’s own terms and include any document links or reference numbers. Thanks.

Industry examples

Manufacturing

Context. A plant-level conduct or ethics target is tracked in a compliance log and approved through a management committee paper.

Adapted request. Please share the conduct target log and the committee paper for [reporting period]. For each target, include the plant or site covered, the starting point used, the milestone date, and the approval reference.

Example response. Target ID: CT-01; Target name: Supplier code rollout; Coverage / scope: All direct suppliers for three plants; Baseline year or starting point: 2025 supplier onboarding status; Baseline description: 42% of suppliers had signed the code; Target date / milestone: 31 Dec 2027; Status: In progress; Approval reference: Ops Committee 14/03/2026; Evidence link: SharePoint/Compliance/CT-01

Financial services

Context. A group-wide integrity or conduct target is maintained in a governance tracker and supported by board pack extracts.

Adapted request. Please send the governance tracker and board paper showing the current target wording, the business area it covers, the baseline used, and the planned completion date for [reporting period].

Example response. Target ID: GOV-04; Target name: Training completion milestone; Coverage / scope: UK and EU front-office teams; Baseline year or starting point: 2026 Q1 completion rate; Baseline description: 68% completed the module; Target date / milestone: 30 Sep 2027; Status: On track; Approval reference: Board pack 22/04/2026; Evidence link: GRC system record #88421

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 how the target was set, what activities or parts of the business it covers, which starting figure was used, and the date by which the aim is meant to be reached.

Context note

Explain what the target means in practice by linking the intended level to the starting point, the covered scope, and the planned timing.

Fluctuation statement

If the target, scope, baseline, or timing has changed, describe what moved, why it changed, and whether the revision affects the overall ambition or only the way it is measured.

Content index entry

G1-3 Targets — [location / page] / [notes]

Download Centre

Preparation tools & forms

Professional preparation tools for G1-3 — 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 ↧

Go deeper · G1-3

Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Explore the ESRS / CSRD course →

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We set out the target’s numeric or qualitative end-point, the unit we use where relevant, and whether the figure is based on an absolute amount or a proportion.An assurer will test whether the stated target basis is clear, internally consistent, and not mixed up with a different metric or unit.Target-setting paper; KPI dictionary or methodology note; approved target register; board or management approval pack; working papers showing how the unit and basis were chosen and checked against the published wording.

We explained which parts of the business the target covers, including any limits we applied to our own sites, upstream or downstream activities, and the countries or regions included.An assurer will probe whether the scope was defined consistently and whether any exclusions or geographic limits were applied deliberately rather than by omission.Scope memo; boundary mapping; consolidation or coverage schedule; value-chain mapping; list of included entities, activities and locations; sign-off showing the scope decision was reviewed before publication.

We stated the time frame for the target and noted any staged steps or interim checkpoints we had set along the way.An assurer will check whether the end date and any stepping-stone dates are supported by source records and whether they match the version approved for disclosure.Target timeline document; milestone tracker; project plan; approval minutes; version-controlled draft of the disclosure; evidence that the published dates agree to the underlying plan.

Where we had a starting point for the target, we disclosed the opening level and the year we used as the reference point for tracking change.An assurer will test whether the baseline was selected on a sound basis, whether the base year is clearly identified, and whether the starting value ties back to source data.Baseline calculation file; source data extracts for the base year; methodology note explaining the baseline choice; audit trail from source records to the disclosed figure; review evidence showing the baseline was checked before issue.

If we did not have a measurable outcome target, we explained whether we still monitored progress and, if so, how we did that.An assurer will probe whether the statement is complete, whether the monitoring approach is real and operating, and whether the disclosure avoids implying a quantified target that does not exist.Monitoring framework; internal reporting pack; meeting notes showing how progress was reviewed; any qualitative indicators used; evidence of management review confirming the wording before publication.

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

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The request goes to the wrong team, so the target figure is pulled from someone who does not own the business plan or the underlying performance data.

Framework language only

The question is asked in ESRS-style terms instead of the organisation’s own wording, and the person answering cannot map it to the right internal metric.

No boundary set

People collect a target without first agreeing which business units, sites, or activities are included, so later figures are not comparable.

Wrong time basis

The team mixes a calendar-year target with a different reporting period, so the number does not line up with the period used elsewhere in the pack.

Mixed counting basis

One source uses headcount, another uses full-time equivalent, and the collection step merges them without noticing the basis is different.

Source labels lost

The original file names, system tags, or table headings are stripped away, so nobody can trace where the target value came from.

Separate groups merged

Targets for different populations are combined into one total even though they should stay separate for the disclosure pack.

No evidence trail

The team saves the number but not the supporting notes, extracts, or approval record, so the source and sign-off cannot be checked later.

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Where judgement is often needed

Set the target boundary when the business changes shape

If a takeover, sale or internal reorganisation changes the group you report on, choose a clear cut-off for what sits inside the target and explain whether the target is restated or left on the old basis.

Handle country-by-country definitions with one internal rule

Where local laws or operating practices define the same topic differently, pick one group-wide interpretation for the target, note any exceptions, and explain how you kept the comparison fair across markets.

Decide who is in scope at the margins

For workers, sites, suppliers or other populations that sit near the boundary, state the inclusion rule you used, why it was chosen, and whether any borderline cases were counted or left out.

Fix the baseline date and keep it consistent

Choose the starting point for the target using one date or period, explain why that point was selected, and say if later restatements were made because the underlying population changed.

Be clear when the starting figure is estimated

If the opening number is not fully measured, disclose which parts were estimated, the method used, and how you will replace or update the estimate when better data becomes available.

Use one timing basis for the target clock

State whether progress is tracked against a calendar year, financial year or another period, and explain any mismatch between the target timetable and the reporting cycle.

Round numbers without hiding the underlying basis

If figures are rounded, say the rounding approach and make sure the published totals still align with the detailed records and the target story.

Aggregate sensitive data before disclosure

When privacy, competition or small sample sizes prevent person-level detail, combine the data to a level that protects individuals and explain the aggregation rule and any resulting limits on precision.

＋ Show 5 more− Show fewer

Examples

Illustrative examples

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

Illustrative (synthetic) example — Consumer goods

We set a 2030 ambition to cut the share of our own operations that is not yet covered by a formal anti-corruption training programme from 18% in our 2024 baseline to 0% by the end of 2030. - The starting point is our 2024 internal review of 500 employees in scope, of whom 410 had completed the programme and 90 had not. - The target applies only to our directly employed workforce in our manufacturing and distribution sites; contractors and joint ventures are outside this measure.

This example shows a quantified end-point, the starting measurement, the group covered by the measure, and the planned completion date.

Illustrative (synthetic) example — Business services

We aim to raise the proportion of our client-facing staff who have completed our anti-bribery refresher from 72% in the 2025 baseline to 100% by 2028. - Our baseline was measured across 250 relevant employees, with 180 already trained and 70 still to complete the refresher. - The measure covers permanent and fixed-term staff in our advisory teams only; temporary agency workers and outsourced service providers are not included.

This example shows the intended end-state, the initial measurement, the people included in the measure, and the deadline for delivery.

Company reportsReal published reports

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How companies report G1-3 in practice

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

Hugo Boss AG

Textiles, Apparel, Footwear and Luxury Goods · Germany · 2024

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Hugo Boss AG’s 2024 Annual Report includes a clear target to reduce emissions by 50% across Scope 1 to 3 by 2030, as stated on page 70. The report partially applies certain ESRS standards related to workforce and resource use targets, noted on page 315. However, several narrative items relevant to this disclosure are not found or unclear in the report.

Bakkafrost P/F

Food Production — Animal Source · Faroe Islands · 2025

Open report →

Bakkafrost P/F’s Integrated Annual Report 2025 includes a clear science-based target to reduce Scope 3 emissions by 52% per tonne of product sold by 2030, based on a 2020 baseline (p.5). The report also provides data on Scope 3 greenhouse gas emissions in tonnes of CO2 equivalent, showing a reduction trend (p.93), and mentions SBTi-validated targets for Scope 1 and 2 emissions reductions (p.23). However, no additional narrative details or broader context about the Scope 3 emissions strategy or progress are found elsewhere in the report.

Continental AG

Tires · Germany · 2025

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Continental AG’s 2025 Annual Report includes a reported value related to targets connected to 2019 production volumes in the tire business, as noted on page 129. The report references targets for Scope 1 and Scope 2 emissions operationalized through specific actions (p.132) and mentions that the baseline year for these targets remains 2019 despite organizational changes (p.128-129). However, no interim targets have been set, and there is no evidence of revalidation of the intensity target since 2020 (p.129, p.161), with no additional quotable narrative found elsewhere in the report.

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Scenarios to work through

A group has set a 2030 target to cut supplier-related bribery incidents in its high-risk procurement category. The draft note says the target is for the whole group, but it does not say whether it covers only direct suppliers or also agents and subcontractors.

QHow should you decide what to include when describing the target’s coverage?

Reveal model answer →Hide answer ↑

Set out the part of the business and the value chain that the target actually covers, using the same boundary the organisation used when it approved the target. If the target applies only to direct suppliers, say that; if it also reaches agents or subcontractors, include them too. Do not leave the reader guessing about the perimeter.

Why this matters · Describe the target’s coverage in plain terms and keep it aligned with the boundary used when the target was set.

A company wants to report a target to reduce confirmed corruption cases by 40% by 2028. The team has two possible starting points: the 2024 incident count, or the average from 2022–2024, and the papers in circulation use both figures.

QWhat baseline should be disclosed, and how should you handle the fact that more than one starting point is being discussed?

Reveal model answer →Hide answer ↑

State the single starting point used to measure progress, and make clear which period or figure it comes from. If the organisation debated more than one option, the report should still present only the baseline that was actually chosen for the target, so readers can track progress from the same reference point.

Why this matters · Use one clear starting point for progress tracking and explain it unambiguously.

A preparer is drafting a target to increase ethics training completion to 95% by 2027. The target was approved for employees in the sales and procurement teams only, but the draft wording says simply that it applies to ‘staff’.

QShould the report keep the broad wording, or narrow it to the group the target was meant to cover?

Reveal model answer →Hide answer ↑

Narrow it to the actual population covered by the target. The description should identify who is in scope in a way that matches the approved target, such as the named functions, locations, or worker groups, rather than using a broader label that would overstate coverage.

Why this matters · Make the target’s scope specific enough that readers can see exactly who is included.

The sustainability team has a target to reduce gifts-and-hospitality breaches by 30% from a 2025 baseline. The board paper says the aim is to reach that level ‘in the medium term’, while the project tracker shows a firm end date of December 2029.

QWhat timeline should be disclosed if the internal documents are not fully aligned?

Reveal model answer →Hide answer ↑

Report the timeline that was actually set for the target and make sure it is consistent with the approved plan. If the organisation has a firm end date, use that date rather than a vague phrase. If the documents conflict, resolve the inconsistency before sign-off so the published timeline is not misleading.

Why this matters · Give a clear end date or period for the target and check that all source documents agree.

Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS

G1-3

within ESRS G1: Business Conduct

Open official source →

Primary

Related & explore

Policies (Business Conduct) → Guide ✓Actions (Business Conduct) → Guide ✓Corruption & Bribery Metrics → Guide ✓Political Influence & Lobbying → Guide ✓Payment Practices → Guide ✓Show all 5 related disclosures →

More in ESRS G1 →Browse full catalogue →Disclosure Library home →Search all disclosures →

Go deeper · G1-3

Learn to prepare this disclosure end-to-end

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Explore the ESRS / CSRD course →

FAQ

Questions this page answers

For G1-3, what data points do I need to gather before I start drafting the disclosure?+−

The page says to prepare four datapoints: target values, target coverage, starting point and delivery date. Use those as the minimum input set before you draft the narrative or table.

How do I use the step-by-step 'how to prepare' section for G1-3 in practice?+−

Use it as a working checklist to move from scoping to drafting, rather than as a policy statement. It is there to help you organise the disclosure, collect the right inputs and avoid missing key fields.

What should I include in the G1-3 scope and methodology so the disclosure is usable?+−

The page points you to define the target values, target coverage, starting point and delivery date clearly enough for a reviewer to follow the logic. Keep the method practical and consistent with the evidence you can show in the pack.

Who should own the G1-3 data collection and sign-off process?+−

The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source the data and explain it. In practice, assign one accountable owner and make sure the evidence pack supports their sign-off.

What evidence do I need to keep for G1-3 to be assurance-ready?+−

The page includes an evidence pack with five items for assurance readiness, plus five assurance claims to verify. Use those together so each reported point can be traced back to supporting documents or records.

What are the five assurance claims for G1-3 and how do I check them?+−

The page says there are five claims to verify, each with a claim, risk and evidence prompt. Use them as a review list to test whether the disclosure is complete, consistent and supported before it goes to assurance.

What are the most common mistakes people make when reporting G1-3?+−

The page lists common reporting gaps and mistakes to help you spot weak points before submission. Use that section as a pre-filing check so you can fix missing data, unclear scope or unsupported statements early.

How do I turn the G1-3 data into a draft disclosure quickly?+−

The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Start with the table or visual, then use the narrative starters to turn the prepared datapoints into a concise draft.

Can I use the synthetic example disclosure on the G1-3 page as a template?+−

Yes, but only as an illustrative guide. The example is synthetic, so use it to understand structure and presentation, then replace every figure and statement with your own company data and evidence.

What is in the G1-3 Download Centre and how should I use it?+−

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.

How can I use the 'From company reports' table for G1-3?+−

It links to real published reports at the pages where the topic is disclosed, so you can see how others present similar information. Use it for practical inspiration on layout and wording, not as a substitute for your own data or methodology.

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	Report A	Report B	Report C
Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

Members see the full datapoint coverage map — ✓ with page references — across 3 real reports, in the companies' own words.

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Targets

Key datapoints to prepare

How to prepare it

Request the target register and supporting evidence

Notes that turn data into a disclosure

Preparation tools & forms

For each claim, check the evidence

Evidence pack to prepare

Common reporting gaps

Mistakes to avoid when collecting the data

Where judgement is often needed

Illustrative examples

How companies report G1-3 in practice

Scenarios to work through

Related framework references

Questions this page answers

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