Disclosure focus
This disclosure asks an organisation to explain how it identifies, tracks and responds to human rights incidents involving its own workforce. In practice, the report should describe the types of incidents it considers, how it records them, and what it does when issues are found, including any follow-up, remediation or escalation. The emphasis is on giving a clear picture of the organisation’s approach rather than listing isolated events without context.
The practical focus is on coverage across the whole workforce and all relevant operations, not just a few well-controlled sites or headline cases. An organisation should be able to show whether its reporting and response processes apply consistently across locations, business units and worker groups, and whether there are any gaps in coverage. The aim is to help readers understand how complete and reliable the organisation’s incident reporting is in practice.
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.
Preparation
Key datapoints to prepare
＋ Show S1-16 sub-elements (LRA working checklist)
Record the number of incidents.
Record the number of human-resources incidents.
Record the amount paid in compensation, in euros.
Record the amount paid in fines, in euros.
How to prepare it
1Set the reporting boundary first: decide which workforce-related incidents fall inside the period and organisation scope you are using for this disclosure, so the same boundary is applied to every figure you report.
2Agree the counting rules before you start collecting data: define what you will treat as an incident, what you will treat as a human-rights-related incident, and how you will separate those two counts from each other.
3Gather the source records that support each number: incident logs, case files, finance records, and any other internal evidence needed to back the incident totals, the human-rights incident total, and the monetary amounts.
4Compile the reported outputs in the required form: provide the two incident counts and the two euro amounts for penalties and compensation, using a clear and consistent method so the figures can be traced back to the underlying records.
5Explain any exclusions, restatements, or changes in method: if a case is left out, reclassified, or counted differently from a prior period, record the reason and the effect on the reported numbers.
6Check the draft against the official source before sign-off: confirm that the scope, definitions, counts, and monetary figures match the underlying evidence and that nothing required by the disclosure has been missed or added.
Request the data
Request the incident log and case outcomes
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What human-rights-related incidents were recorded in the period, and what amounts were paid or imposed as a result?
Use your organisation’s own case, grievance, conduct, complaints, or incident terms first, then map them to the disclosure wording when you prepare the reporting pack. Keep the request in the language the owner already uses internally, and check the source material before sign-off.
Weak request
Please provide all human rights incidents and related fines and compensation for the period.
Why it fails: It uses framework language that many teams do not use day to day, so the owner may not know which register, case type, or payment fields to pull. It also leaves out the boundary, counting approach, and source system, which makes the extract hard to verify.
Better request
Please pull the [reporting period] extract from your [case log / grievance register / conduct tracker] for the records you would normally treat as [your internal case categories]. For each record, include the case reference, dates, status, internal label, and any amounts paid or imposed, split between [your terms for sanctions] and [your terms for compensation]. Please also note the source system, the counting rule used, and any exclusions.
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 how the organisation defined each incident measure, how it identified the work-related subset, and the basis used to total any penalties and compensation amounts.
Context note
Explain what the counts and amounts indicate about the scale of incidents and their financial consequences during the reporting period.
Fluctuation statement
If any figure moved materially, note the main operational, legal, or reporting reasons that drove the change and whether it reflects a one-off event or a broader shift.
Content index entry
S1-16 Human Rights Incidents — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
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
Asking the policy team or legal team for the figures, instead of the case-handling owner who tracks incidents in day-to-day operations, leads to incomplete or delayed data.
Framework language only
Requesting the numbers using disclosure labels rather than the organisation’s own case, complaint, or incident terms means the right records may never be pulled together.
No clear scope
Failing to state which parts of the business, sites, or worker groups are in scope causes teams to mix in records that should have been left out.
Wrong time basis
Pulling cases by report date, close date, or payment date without fixing one consistent period can shift incidents into the wrong reporting year.
Mixed counting method
Combining raw incident counts with separate human-rights case counts, or mixing case totals with euro amounts, produces figures that cannot be reconciled.
Source labels lost
Copying data into a summary sheet without keeping the original case reference, category, or outcome label makes later checks against the source file difficult.
Separate groups merged
Putting employee cases, contractor cases, and other affected groups into one undivided total hides which population each number came from.
Missing evidence trail
Collecting the totals without the underlying file name, date extracted, and preparer note leaves no audit trail for review and sign-off.
No sign-off record
Sending the draft numbers forward without a named reviewer and approval date means nobody can show who checked the figures before they were used.
Where judgement is often needed
Set the cut-off for counting events that span a reporting date
Choose one clear rule for whether an incident is counted when it starts, when it is confirmed, or when it is closed, then use that same timing consistently and explain it in your note.
Decide how to treat a business bought or sold during the year
State whether you include events and amounts from the acquired or disposed operation for the part of the year it was under your control, and describe any boundary change so readers can see why the year-on-year figure moved.
Handle local legal labels and internal case types with one mapping rule
If different countries or sites use different labels for the same kind of event, map them to one internal category set, explain the mapping, and note any cases that could not be aligned cleanly.
Define the edge of the workforce and other people linked to your operations
Make a documented call on whether to include people just outside your direct payroll but still tied to your activities, then disclose the scope rule and any exclusions that materially affect the count.
Separate confirmed cases from allegations or open investigations
Use one basis for the count and say whether it covers only substantiated cases or also unclosed matters, then explain how you avoid double counting when a case moves from allegation to confirmed outcome.
Choose between exact records and reasoned estimates for money amounts
Where case-level amounts are incomplete, use a consistent estimation method, label the figure as estimated, and explain the source data and assumptions behind the amount reported.
Decide whether to report gross amounts or netted figures
Pick one approach for fines and compensation, state whether offsets, recoveries, or reversals are included or excluded, and keep the same basis across the period unless you explain a change.
Set a rounding rule that does not distort small totals
Apply one rounding convention to counts and euro amounts, and if rounding changes a small total in a noticeable way, say so and show the unrounded basis in working papers.
Protect personal data by grouping low-volume cases before disclosure
If naming or splitting cases would expose individuals, combine the data into a broader group, explain the aggregation rule, and make clear that the published total still covers the full set of relevant incidents.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
: we report four workplace incidents in the year, of which two involved our own staff. We also show the related financial outcomes: €18,000 paid in penalties and €42,000 paid in compensation.
Illustrative only; figures are invented for training purposes and are internally consistent.
Illustrative (synthetic) example — Logistics
: during the reporting period we recorded six workplace incidents, including three affecting our employees. The associated financial impact was €9,500 in penalties and €27,500 in compensation.
Illustrative only; figures are invented for training purposes and are internally consistent.
How companies report S1-16 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Indra Sistemas, S.A.
Software and Services · Spain · 2025
Indra Sistemas, S.A.'s Sustainability Report 2025 includes some data on incidents of corruption and bribery, noting the total number of confirmed incidents, though specific figures are not provided (p.159). The report also details accident metrics, including fatalities and accident frequency rates among its workforce over multiple years (p.125). However, there is no clear or quotable narrative evidence found in the report regarding the company’s human rights policies or due diligence strategies, despite brief mentions of rights identification and due diligence strategy for customers (p.98, p.235).
Continental AG
Tires · Germany · 2025
Continental AG's 2025 Annual Report provides data on fines, penalties, and compensation related to human rights incidents, indicating zero amounts paid and zero known incidents on page 182. The report also mentions figures related to human rights matters excluding discrimination, with values of 56 and 139, though the context is unclear (p.182). Additionally, the report states that fines, penalties, and compensation paid during the reporting year are included and related expenses as defined by ESRS are reported (p.197). However, no further narrative or detailed explanation on these disclosures is found in the report.
Prysmian S.p.A.
Electrical Equipment and Machinery · Italy · 2025
Prysmian S.p.A.'s 2025 Integrated Annual Report provides data on human rights incidents, reporting no severe cases in FY24 and detailing 104 incidents overall, with no fines, penalties, or compensation paid related to these incidents (p.202). The report partially addresses diversity, equity, inclusion, and wellbeing through a mention of the HR and Group DE&I and Wellbeing VP, but lacks headline values or comprehensive metrics in this area (p.267). There is no clear evidence on other specific human rights disclosures or detailed complaint investigations beyond internal handling, leaving some aspects of the disclosure unclear or not found in the report.
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Scenarios to work through
During the year, the group logged 7 incidents in its grievance and case-tracking system. After review, 3 of those were confirmed as human-rights related, and the rest were health-and-safety, conduct, or payroll matters.
QHow should the preparer separate the incident totals for the disclosure, and what should be kept distinct from the human-rights subset?
Reveal model answer →Hide answer ↑The preparer should report the full incident count as 7, then show the human-rights-related subset as 3. Any amounts linked to penalties or compensation should be tracked separately from the counts, because the disclosure asks for both the number of events and the financial consequences, not one blended figure.
Why this matters · Keep the overall case count separate from the human-rights subset, and do not mix those counts with money amounts.
A supplier complaint led to a settlement payment of €120,000 and a regulator later imposed a €30,000 penalty. Internal records show both amounts relate to the same human-rights matter.
QShould the preparer combine the two amounts into one figure, or present them separately for the disclosure?
Reveal model answer →Hide answer ↑They should be shown separately: €30,000 for the penalty and €120,000 for compensation. Even when both arise from the same matter, the disclosure needs the two financial effects distinguished so users can see what was paid as a sanction and what was paid to remedy harm.
Why this matters · Separate sanctions from compensation, even when they come from the same case.
The legal team says one case involved a labour-rights breach, but the operations team argues it was only a contract dispute because the worker was later rehired. The incident file contains witness notes, a settlement agreement, and an internal investigation summary.
QWhat should the preparer do before deciding whether this case belongs in the human-rights count?
Reveal model answer →Hide answer ↑The preparer should review the available facts and use the organisation’s own assessment to decide whether the matter belongs in the human-rights subset. A label from one team is not enough on its own; the classification should follow the substance of the incident and be applied consistently across the reporting period.
Why this matters · Classify cases by their substance, not by a single department’s label.
At year-end, the company has 5 open cases and 2 closed cases that were confirmed as human-rights related. Finance has already booked €18,000 of compensation for one closed case, while a regulator has not yet decided whether any penalty will be issued.
QWhat should the preparer include in the disclosure when some matters are still unresolved?
Reveal model answer →Hide answer ↑The preparer should include the confirmed human-rights incident count for the period, including closed and open matters if they fall within the reporting boundary used for the disclosure, and should report only amounts that are known at the reporting date. If no penalty has been decided yet, it should not be included as a final amount; the compensation already booked can be reported if it is attributable to the relevant incident.
Why this matters · Use the reporting-date facts for money amounts, and do not treat an undecided penalty as a completed figure.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
For S1-16, what data points do I need to collect before I start drafting the disclosure?+−
The page says to prepare four datapoints: incident count, HR case count, penalty amount and compensation amount. Use those as the starting checklist before you draft anything.
How do I use the step-by-step 'how to prepare' section for S1-16 in practice?+−
Use it as a working sequence for getting the disclosure ready, rather than as a final answer. It is there to help you organise scope, data collection, evidence and drafting in a practical order.
What should I include in the evidence pack for S1-16 assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness. Use it alongside the assurance claims so you can show where the numbers came from and how they were checked.
What are the six assurance claims on the S1-16 page and how should I use them?+−
The page provides six claims with related risks and evidence prompts. Treat them as a checklist for testing whether the disclosure is supported, rather than as a substitute for your own controls and records.
What are the common reporting gaps or mistakes for S1-16 that I should avoid?+−
The page lists common gaps and mistakes to help you spot weak points before submission. Use that section to check whether your scope, data and evidence are consistent and complete.
How can I turn the S1-16 data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those to turn the prepared data into a first draft that is easier to review and assurance-test.
How should I use the synthetic illustrative example disclosure for S1-16?+−
The example is there to show what a worked-up disclosure can look like, including a quantitative table. It is synthetic, so use it for structure and presentation only, not as a real reporting benchmark.
What is in the S1-16 Prep & Assurance workbook and when should I use it?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation work, track the assurance checks and keep the disclosure build in one place.
What is the printable Library Card for S1-16 and how is it different from the workbook?+−
The Download Centre also includes a printable Library Card in .pdf format. The page presents it as a companion resource, so it is useful for quick reference while the workbook is better for active preparation.
Does the S1-16 page show real company report examples I can use as references?+−
Yes. The page includes a 'From company reports' table that links to real published reports at the pages where the topic is disclosed, which can help you see how others present similar information.
Can I use the S1-16 page to check whether my disclosure is ready for assurance?+−
Yes. The page is built around assurance readiness, with claims to verify, evidence-pack items and common mistakes to check. It is designed to help you spot gaps before a reviewer does.
More questions this page can help with
S1-16 own workforce disclosure: what should an HR data owner gather first?S1-16 incident count and HR case count: how do I prepare the numbers for drafting?S1-16 penalty amount and compensation amount: what evidence should support the figures?How do I use the S1-16 step-by-step preparation section with the workbook?What does the S1-16 evidence pack contain for assurance review?What are the S1-16 common reporting gaps before finalising the draft?How do I turn the S1-16 illustrative example into my own disclosure draft?Where can I find real published reports linked from the S1-16 page?What should a sustainability manager check before sending S1-16 for assurance?How do I use the S1-16 content-index line in a draft report?What is the S1-16 plain-language explainer meant to help me do?Can the S1-16 page help me build an evidence pack and draft narrative at the same time?
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