Disclosure focus
This disclosure asks an organisation to explain how it engages with its own workforce and how people can raise concerns or complaints. In practice, the report should show whether workers have ways to speak up, whether those channels are available in a way that people can actually use, and how the organisation responds when issues are raised.
The practical focus is on coverage and accessibility across the organisation, not just on a few well-known sites or headquarters. A useful response should make clear whether the arrangements apply across operations, locations and worker groups, and whether there are differences in how they work in practice for different parts of the workforce.
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 S1-2 sub-elements (LRA working checklist)
Describe how people or groups can be engaged.
Name the groups singled out for attention, such as women, migrants, and people with disabilities.
State whether any agreements are in place.
Explain how far those agreements reach.
Set out the areas or topics they cover.
List the ways engagement is carried out.
Record the issues or complaints that were brought forward.
Show which reporting or complaint routes are available.
Explain how you judge whether those routes work well.
State whether a grievance route exists.
Report the share of cases that were closed out.
Summarise the steps taken in response.
State how many cases were fixed through remediation.
Describe the process used to put things right.
How to prepare it
1Set the reporting boundary first. Decide which parts of the business, workforce and value chain you will cover for this disclosure, then keep that boundary consistent across the rest of the response.
2List the worker groups and participation routes you actually use. Identify the relevant groups, such as women, migrant workers and people with disabilities where applicable, and record the ways they can engage with the organisation.
3Check whether formal worker agreements exist and define their reach. Note if there are any such arrangements, then state the scope they apply to and the coverage they provide in practice.
4Map the complaint and issue-handling routes. Capture the channels people can use, whether a grievance route is in place, the cases raised through it, the share resolved, and your view on how well it works.
5Describe how problems are put right. Set out the process used to remediate issues, note which cases were remediated, and summarise the actions taken to address them.
6Document any exclusions, scope changes or judgement calls, then reconcile the draft against the official source. Make sure the final wording matches the underlying datapoints and that every required item is covered before sign-off.
Request the data
Request employee engagement and grievance records
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do we show the ways people can raise issues, how those issues are handled, and what follow-up or remedy has been put in place during the reporting period?
Use your organisation’s own terms first, then map them to the reporting disclosure. For example, if you call these routes, speak-up lines, case logs, employee forums, union consultations, or resolution actions, use those labels in the request and only translate them afterwards for reporting.
Weak request
Please provide the ESRS S1-2 engagement and grievance mechanism data, including stakeholder engagement methods, grievance channels, remediation, and effectiveness evidence.
Why it fails: It uses framework language that may not match how the business actually records the information, so the owner may not know which systems, teams, or case types to pull. It also does not specify the period, boundary, counting basis, or the exact internal records needed to support the figures and narrative.
Better request
Please send the people issue-handling and speak-up records for [reporting period] for [site/business unit]. We need the routes people use to raise concerns, any groups you tailor them for, any agreements that set out how they work, the channels available, whether a formal case route exists, the number of cases raised and resolved, how you assess whether the process works, and the remedy or follow-up actions taken. Please use your own team labels and include the source extract, date pulled, and any counting notes.
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
Explain which groups were included in the engagement review, what counted as an engagement method, how agreements were identified, and how scope and coverage were defined for the reported arrangements.
Context note
Set out what the figures show about how the organisation engages with people, what channels are available for raising concerns, how many cases were received and resolved, and what remediation steps were taken where issues were found.
Fluctuation statement
If the numbers changed from one period to the next, link the movement to changes in engagement activity, channel use, case volumes, resolution performance, or the extent of remediation work carried out.
Content index entry
S1-2 Engagement & Grievance Mechanisms — [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
The request goes to the wrong team, so the data comes from people who do not run the staff channels, case handling, or follow-up actions in practice.
Framework language only
The data call uses disclosure terms instead of the organisation’s own labels, and the source team cannot map them cleanly to its internal records.
No scope set
The collector never defines which workforce groups, sites, or entities are in scope, so the figures mix together records that should have been kept separate.
Wrong period basis
The team pulls numbers from a different reporting window or cut-off date, so the dataset does not match the period being reported.
Mixed counting basis
Some fields are counted by people, others by cases or actions, but the source files do not state the basis used, so the totals cannot be compared reliably.
Source labels lost
Original system names, case IDs, or channel tags are stripped out during collection, making it impossible to trace each figure back to the underlying record.
Populations merged
Records for different groups, such as women, migrant workers, or people with disabilities, are combined into one pool even though they should be tracked separately.
Missing evidence trail
The pack is saved without the supporting file names, dates, or approver trail, so no one can show where the data came from or who checked it.
No sign-off record
The final dataset is used before the owner has confirmed it, leaving no clear trail that the numbers were reviewed and accepted before drafting.
Where judgement is often needed
Acquisitions and disposals during the year
Decide whether to include only the people and channels in the business at the reporting date or to also reflect parts added or removed during the year, and explain the cut-off used.
Different local labels for the same worker groups
Where countries use different labels or legal categories, map them to a single internal grouping approach and state the mapping rule so readers can see how like-for-like groups were combined.
People just outside the formal workforce
Set out whether contractors, agency staff, interns, or other near-scope groups are counted in the engagement and complaint channels, and explain the boundary if they are partly included or excluded.
Which channels count as a complaint route
Choose whether to list only dedicated issue-reporting routes or also broader speaking-up, HR, union, or hotline channels, and describe the basis for that choice.
Agreements with worker representatives
If there are arrangements with employee representatives, clarify which parts of the workforce they cover and whether coverage is full, partial, or limited to certain sites or countries.
Counting cases and measuring resolution
State whether case numbers and closure rates are based on opened cases, closed cases, or another internal measure, and keep the same basis across the period or explain any change.
Effectiveness judged by numbers or by review
Explain whether the assessment of how well the channels work is based on operational metrics, management review, user feedback, or a mix of these, and disclose the method used.
Privacy-driven grouping of sensitive data
Where small numbers could identify individuals, combine categories or locations before reporting and say that the figures were aggregated to protect privacy.
Estimated figures versus system extracts
If some data come from manual estimates rather than a system report, identify the estimated items, the source used, and any known limits on accuracy.
Rounding and presentation of percentages
Apply one rounding rule consistently to counts and percentages, and note it if rounding means subtotals do not add exactly to the total.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food manufacturing
We used a mix of staff forums, one-to-one interviews, site walkabouts and worker-representative meetings to hear from people most likely to face barriers, including women, migrant workers and colleagues with disabilities. We had written arrangements with 3 of our 5 main labour suppliers, covering 420 of 500 workers in scope; our reporting channels were open to all staff and contractors, 18 concerns were logged, 15 were closed out, and we judged the process effective because most cases were handled within target times and users said the routes were easy to access. - Where harm had already occurred, we used case-by-case fixes such as pay corrections, schedule changes, equipment adjustments and manager retraining; 11 matters were fully put right during the period. - The figures above are internally consistent and illustrative only.
Synthetic, practitioner-facing example showing how a company might describe worker engagement, reporting routes, case handling and remedy in plain language.
Illustrative (synthetic) example — Logistics and warehousing
We gathered views through toolbox talks, shift huddles, anonymous surveys and meetings with elected worker representatives, with extra outreach to women, migrant colleagues and employees with disabilities. We had formal agreements with 2 of our 4 key service partners, covering 260 of 320 people in the relevant workforce; our speaking-up routes included phone, web and in-person options, 9 matters were raised, 8 were closed, and we assessed the system as working well because access was broad and most issues were settled without delay. - When something needed fixing, we used tailored remedy steps such as reinstating hours, replacing damaged equipment, adjusting duties and giving refresher training; 6 cases were remedied in full. - This is a made-up example for training and review.
Synthetic, practitioner-facing example showing a different sector and a different mix of engagement, reporting and remedy practices while keeping the figures internally consistent.
How companies report S1-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Aena S.M.E., S.A.
Air Transportation — Airport Services · Spain · 2025
Aena S.M.E., S.A.'s 2025 Sustainability report includes information on channels for its own workers to raise concerns and actions taken on material impacts affecting its workforce (p.70). It also addresses processes to remediate negative impacts and channels for value chain workers to raise concerns (p.183). However, the report provides unclear context on the effectiveness of these actions (p.70, p.233), and no clear disclosure was found on other related narrative items.
Enagás, S.A.
Gas Utilities · Spain · 2025
Enagás, S.A.'s 2025 Annual Report provides partial context on its human rights due diligence system as established in its Human Rights Policy, though it does not present clear headline values or detailed disclosures (p.200). The report includes some related context on engagement with affected communities, noting that negative impacts can be raised through such engagement, but this is not a clear or comprehensive disclosure of the required datapoint (p.209). Several expected narrative items are not found in the report, indicating a lack of full coverage or clarity on specific social information related to affected communities.
Hugo Boss AG
Textiles, Apparel, Footwear and Luxury Goods · Germany · 2024
Hugo Boss AG’s 2024 Annual Report partially covers employee engagement, noting the use of the annual Great Place to Work survey conducted Group-wide by an external service (p.92). The report also references engagement in the context of the Combined Non-Financial Statement and assurance processes (p.338) and mentions grievance mechanisms and remediation processes related to workforce engagement, though it states some related standards are only partially applied or not material (p.315). However, the report lacks clear headline values or comprehensive disclosures specifically on employee engagement, with several expected narrative items not found or unclear.
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Check your understanding
Scenarios to work through
A preparer is drafting the people section and has one consultation log for the year, but it only covers office staff. The business also has migrant workers and employees with disabilities, and there were separate listening sessions for each group.
QHow should the team decide what to include about who was consulted and how the consultation was done?
Reveal model answer →Hide answer ↑They should describe the groups that were identified for engagement, including the relevant worker groups that were actually considered, and explain the methods used to engage them. If different approaches were used for different groups, the description should make that clear rather than collapsing everything into one generic statement.
Why this matters · Report both the groups reached and the practical ways they were engaged, using wording that matches the organisation’s own process.
A grievance hotline exists for all staff, but the team is unsure whether to present it as a formal complaint route because some issues are also handled through line managers and HR. During the year, 18 cases were logged and 15 were closed.
QWhat should the preparer do when describing the complaint route and the cases raised through it?
Reveal model answer →Hide answer ↑They should explain the channels available for raising concerns in plain business terms, then state whether the organisation has a dedicated complaint-handling route. They should also disclose the number of cases raised through that route, using the same basis consistently so the figures are understandable and comparable within the report.
Why this matters · Describe the available routes and the volume of cases in a consistent way, without mixing different reporting bases.
The company has a worker feedback process in place, but the team has not checked whether it actually works well. They know that 12 matters were closed during the year, while 3 remain open, and they have no documented review of whether users trust the process.
QHow should the team judge whether to say the process is effective?
Reveal model answer →Hide answer ↑They should not rely only on the existence of a process or on closure numbers. The disclosure should explain how the organisation assessed whether the route works in practice, using evidence such as how people can access it, whether issues are handled in a timely way, and whether the process is trusted by the people it is meant to serve.
Why this matters · Effectiveness is a judgement about how well the process works in practice, not just whether it exists or how many cases were closed.
A worker complaint about unsafe conditions was resolved by changing the shift pattern and providing new protective equipment. Another complaint about pay was closed after a discussion, but no follow-up action was taken. The draft report currently says only that matters were “handled”.
QWhat should the preparer include about remedy and follow-up actions?
Reveal model answer →Hide answer ↑They should explain the process used to put things right, identify which matters were actually remedied, and describe the actions taken in response. Where the response was a process outcome rather than a fix, that should be made clear so readers can see the difference between closing a case and addressing the underlying issue.
Why this matters · Separate case closure from real remedy, and describe the concrete actions taken to address the issue.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I prepare disclosure S1-2 on own workforce engagement using this page?+−
Use the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page is designed to help you turn those inputs into a draft disclosure, not to replace your own judgement or internal process.
What data do I need to collect for S1-2 own workforce engagement?+−
The page lists the core datapoints to gather, including engagement approach, priority groups, methods, agreements, reporting channels, grievance route, issues raised, closure rate, channel effectiveness, remedy process, remedied cases and remedial actions. Treat that list as the starting point for your data request and evidence check.
How should I define the scope and methodology for S1-2 own workforce engagement?+−
The page gives a step-by-step preparation section and a set of datapoints that help you frame scope and method, such as who was engaged, how they were engaged, and what channels or grievance routes were used. It does not set a formal methodology, so you need to align the page to your organisation’s own approach.
Who should own the S1-2 own workforce engagement disclosure in practice?+−
The page is aimed at sustainability and ESG managers, HR teams, data owners and assurance reviewers, so ownership usually needs to sit with whoever can coordinate those inputs and evidence. Use the page to split responsibilities across content, data, and assurance readiness rather than leaving it with one person alone.
What evidence pack do I need for assurance on S1-2 own workforce engagement?+−
The page includes an evidence pack with five items for assurance readiness, plus six assurance claims to verify with claim, risk and evidence. Use those materials to build a traceable pack that supports the numbers and narrative you plan to disclose.
What are the common mistakes or reporting gaps for S1-2 own workforce engagement?+−
The page has a section on common reporting gaps and mistakes, which is useful for checking whether your draft is complete and internally consistent. Use it as a final review step before sign-off and assurance.
How do I use the Prep & Assurance workbook for S1-2 own workforce engagement?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise preparation and assurance work. Use it alongside the page’s datapoints, evidence pack and assurance claims to build a working draft.
How do I turn the S1-2 own workforce engagement data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. That gives you a practical way to convert your collected data into a first draft and structure the supporting narrative.
Can I use the synthetic example disclosure on S1-2 own workforce engagement as a template?+−
Yes, but only as an illustrative starting point. The example is explicitly synthetic, so you should adapt it to your own data and make sure any quantitative table remains internally consistent.
Where can I find real company report examples for S1-2 own workforce engagement?+−
The page includes a 'From company reports' table that links to real published reports where the topic is disclosed. Use it to see how others present similar information, but do not treat it as a substitute for your own disclosure approach.
More questions this page can help with
S1-2 own workforce engagement checklist for ESG managerS1-2 own workforce engagement data points listS1-2 own workforce engagement evidence pack itemsS1-2 own workforce engagement assurance claimsS1-2 own workforce engagement common mistakesS1-2 own workforce engagement workbook downloadS1-2 own workforce engagement draft narrative startersS1-2 own workforce engagement reporting channels and grievance routeS1-2 own workforce engagement remedial actions and case closure rateS1-2 own workforce engagement synthetic example disclosureS1-2 own workforce engagement company report examplesS1-2 own workforce engagement plain-language explainer
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