Disclosure focus
This disclosure asks an organisation to explain the actions it is taking, or plans to take, to address material impacts, risks and opportunities connected to its own workforce. It is not just a list of policies: the report should show what is being done in practice, what resources are being committed, and how those actions are intended to respond to the issues that matter most for workers.
The practical focus is on whether the organisation’s response is broad enough and targeted enough to be credible. That means looking across the relevant parts of the business, not only at a few well-performing sites or headline initiatives, and showing where actions are being rolled out, where they are still limited, and what resources support delivery.
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 S2-3 sub-elements (LRA working checklist)
Record the measures put in place.
Note the checks carried out.
Set out the training or support provided to build capability.
Describe how suppliers were engaged.
State the steps taken.
Identify the kind of impact involved.
Explain which contractual or commercial levers were used.
Summarise the audit findings.
Set out the key performance measures used.
Report supplier performance ratings.
Give the count of incidents.
Classify how serious the incidents were.
Describe the incident categories.
How to prepare it
1Set the reporting boundary first: decide which suppliers, sites, contracts, and time period sit inside this disclosure, and keep that scope consistent across the narrative and any figures.
2Translate each required item into your internal data fields: separate the actions you carried out, the supplier engagement work, any audits, capacity-building activity, the type of impact, the response taken, the leverage you used, the performance measures, and the incident details.
3Gather source records before drafting: pull together action logs, supplier communications, audit files, training records, KPI outputs, scorecards, and incident registers so each statement can be traced back to evidence.
4Build the disclosure from the evidence in a clear order: describe what was done, how suppliers were engaged, what audits and capability-building took place, what impacts were identified, what response was used, and what the relevant measures and incident information show.
5Explain any gaps, exclusions, or changes in method: if a data point is not available, if a supplier group is left out, or if a calculation or classification approach changed, state that plainly and keep the explanation aligned to the scope you set.
6Check the final draft against the official source before sign-off: confirm every required item is covered, the wording matches the underlying evidence, the numbers and labels are internally consistent, and nothing has been omitted or overstated.
Request the data
Request supplier action and monitoring evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions have we taken with suppliers, what leverage did we use, and what evidence shows the follow-up, checks, and incident tracking for the reporting period?
Use your own supplier-management language first, then map it to the disclosure. For example, if your team talks about vendor remediation, corrective actions, scorecards, site checks, or supplier incidents, use those terms in the request and only translate them afterwards for reporting.
Weak request
Please provide the ESRS S2:S2-3 actions and resources data for suppliers, including all required datapoints and evidence.
Why it fails: It uses framework language that many operational teams do not use day to day, so the owner may not know which systems, records, or local terms to pull from. It also does not say what period, category, or source file is needed, so the response is likely to be incomplete or hard to map.
Better request
Please send the supplier action and monitoring pack for [reporting period] for [business area / category]. Include the actions taken, supplier follow-up, audits or checks, training or coaching, any contract or commercial levers used, the scorecard or KPI results, and the incident count with type and severity. Use your team’s own wording and add the source system, extract date, and supporting files so we can map it for reporting.
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 how the company defined each supplier-related measure, what data sources were used, the reporting period covered and any rules used to classify actions, performance measures, audit findings and incidents.
Context note
Set out what the figures show about how the company is working with suppliers, how it is tracking supplier performance and what the incident data indicates about the nature and seriousness of issues identified.
Fluctuation statement
If the numbers moved materially, describe the main operational reasons for the change, such as more supplier engagement, a different audit programme, changes in performance scoring or a shift in the mix or seriousness of incidents.
Content index entry
S2-3 Actions & Resources — [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
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The team asks a policy or reporting contact instead of the people who actually run supplier engagement, audits, training, or incident tracking, so the data comes back incomplete or second-hand.
Framework language only
The request is sent using disclosure labels rather than the organisation’s own operational terms, and the business cannot map the ask cleanly to its records.
Unclear boundary
No one defines which suppliers, sites, contracts, or business units are in scope, so different teams pull different populations and the final set is not comparable.
Wrong time basis
Data is gathered using a different period, cut-off, or snapshot date from the one used elsewhere, which makes the figures and narrative impossible to align.
Mixed counting method
One source counts events, another counts suppliers, and a third counts actions, but the team combines them without separating the basis, so the totals are misleading.
Source labels lost
The original names from the system, audit file, or tracker are replaced too early, so later reviewers cannot trace each figure back to the exact source record.
Populations merged
Suppliers with different risk levels, regions, or treatment paths are rolled into one file even though they should stay separate, which hides the real pattern in the data.
Missing evidence trail
The team stores the numbers but not the supporting file names, dates, owner details, or approval history, so nobody can show how the dataset was built or checked.
No sign-off record
The final extract is circulated without a clear review and approval trail, so there is no reliable record of who checked the data before it was used.
Where judgement is often needed
Set the reporting perimeter after buy-ins and sell-offs
Use the same cut-off date and consolidation logic across the period, and explain any business units added or removed so readers can see why the action list, supplier work and incident counts changed.
Decide how to handle country-by-country wording differences
Where local labels or legal categories do not line up, map them to one internal description, state the mapping used, and note any places where the local meaning is broader or narrower.
Choose whether borderline suppliers are in or out
If a supplier sits near your operational boundary, apply one consistent rule for inclusion, then disclose that rule and any material exceptions so the scope of actions and checks is understandable.
Fix the timing basis for actions and results
State whether you are using the position at period end, the full-year average, or another cut-off, and keep that basis consistent for actions taken, audits, training and performance measures.
Separate what was measured from what was estimated
When direct evidence is incomplete, say which figures come from records and which rely on estimates or proxies, and explain the method used to fill the gaps.
Round numbers without losing the story
Apply one rounding rule across the disclosure, and check that rounded subtotals still reconcile to the total so the count of incidents, audits or trained people remains coherent.
Aggregate sensitive people data carefully
If privacy rules prevent naming small groups or sites, combine the data to a level that protects individuals, and say that the figures are grouped for confidentiality.
Explain how overlapping actions are counted
Where one initiative covers more than one issue, describe the counting rule you used so the same work is not double-counted across supplier engagement, audits, capacity building or incident follow-up.
Clarify how performance scores are built
If supplier scores come from several checks or weightings, disclose the main inputs and the scoring basis so users can understand what the score reflects and compare it with audit results.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Apparel manufacturing
We are using a supplier improvement programme to address labour-rights risks in our cut-and-sew and fabric supply base, and this example is synthetic and for illustration only. - We carried out 24 supplier reviews and 18 site audits across 30 direct suppliers; 12 suppliers received corrective-action plans, 9 completed our training on working hours and grievance handling, and 6 were supported through follow-up coaching. - The main issue type was excessive overtime, alongside wage-payment delays and weak worker voice channels; we used contract terms, order-volume discussions, and escalation meetings to secure remediation, and our supplier scorecard averaged 78/100, with audited sites averaging 82/100 on labour controls and 4 audits showing no major findings, 10 with minor findings, and 4 with significant findings. - During the period we recorded 7 incidents, including 4 overtime breaches, 2 wage-delay cases, and 1 retaliation allegation; we classified 2 as high severity, 3 as medium, and 2 as low.
Synthetic illustration only; figures are invented for training and are internally consistent.
Illustrative (synthetic) example — Food processing
We are applying supplier controls to reduce health-and-safety and forced-labour risks in our agricultural inputs and packaging chain, and this example is synthetic and for illustration only. - We completed 16 supplier engagements and 14 audits across 22 suppliers; 8 suppliers were placed on improvement plans, 11 managers and buyer teams received refresher training, and 5 suppliers took part in joint workshops on recruitment practices and site safety. - The main harm types were unsafe working conditions, recruitment-fee exposure, and restricted freedom to leave employment; we relied on purchasing commitments, contract clauses, and escalation with senior supplier contacts, while our supplier performance index averaged 74/100 and audited suppliers averaged 79/100, with 3 audits clean, 8 showing limited issues, and 3 showing material issues. - We logged 5 incidents in total, made up of 2 safety events, 2 recruitment-fee complaints, and 1 passport-retention case; 1 was classed as severe, 2 as moderate, and 2 as minor.
Synthetic illustration only; figures are invented for training and are internally consistent.
How companies report S2-3 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Danone S.A.
Food Production — Animal Source · France · 2025
Danone's 2025 Universal Registration Document reports that 3,159 supplier entities were registered on the Sedex or EcoVadis platforms, with 691 audits conducted on Group tier 1 suppliers, of which 587 contained critical non-conformities (p.280, p.356, p.368). The report also notes the use of annual SMETA audits as a key performance indicator (p.280). However, there is no quotable evidence found regarding specific narrative details or numeric values related to human rights impacts or targets in the value chain beyond these audit figures.
Enagás, S.A.
Gas Utilities · Spain · 2025
Enagás, S.A.’s 2025 Annual Report provides some references related to human rights and governance, mentioning impacts and channels for value chain workers to raise concerns (p.85, p.198) and addressing supplier reputational controls linked to corruption and bribery risks (p.75). The report also notes risk management measures including supplier diversification and long-term agreements (p.34), as well as cybersecurity strategies (p.30). However, no direct or detailed narrative or numeric evidence specifically addressing the disclosure was found in the report.
Bakkafrost P/F
Food Production — Animal Source · Faroe Islands · 2025
Bakkafrost P/F’s Integrated Annual Report 2025 provides partial narrative context on engagement with suppliers to promote better practices and diversify the supplier base to reduce dependency (p.152), as well as on audits being reported and discussed at Board meetings with the Board’s expertise noted (p.61). However, the report lacks headline values or specific quantitative data related to these disclosures, and no direct evidence was found regarding processes for engaging with value chain workers or taking action on material impacts (p.152). Overall, the report offers some supporting context but does not fully cover the disclosure with detailed or measurable information.
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Scenarios to work through
A preparer has a short list of supplier-facing steps for a labour-rights issue: revised contract clauses, a corrective action plan, and extra site visits. The draft also mentions a training budget, but it is not clear whether that budget was actually used this period.
QWhich of these items should be described as carried out, and which should be treated separately as resources made available?
Reveal model answer →Hide answer ↑The write-up should clearly separate what was put into action from what was set aside to support the work. The contract changes, corrective plan, and site visits belong in the actions section if they were actually done; the training budget belongs in the resources section only if it was allocated or used as part of the response. Do not blur the two, because the reader needs to see both the steps taken and the support behind them.
Why this matters · Keep actions and supporting resources distinct so the account shows both delivery and backing.
A team has responded to a serious supplier labour issue by tightening purchase terms, increasing follow-up calls, and using its buying power to push for change. The draft report says the issue was “addressed”, but it does not explain what kind of harm was involved or how the company influenced the supplier.
QWhat extra detail needs to be added so the response is understandable to a reader?
Reveal model answer →Hide answer ↑The description should say what sort of labour-related harm the company was dealing with, what it actually did in response, and how it used its commercial relationship to encourage change. A reader should be able to see whether the response relied on contract terms, purchasing decisions, or another form of business influence, rather than only seeing a generic statement that the matter was handled.
Why this matters · Explain the harm, the response, and the business leverage used, not just the headline outcome.
A preparer has performance data from supplier scorecards and audit findings, but the numbers are mixed with narrative comments. One supplier improved on the scorecard after training, while another failed an audit and was given a corrective plan; the draft does not show which evidence supports which part of the story.
QHow should the evidence be organised so the report is usable and credible?
Reveal model answer →Hide answer ↑The report should link the measures used to the relevant response, rather than leaving the data as a loose bundle. Scorecard results, audit findings, and any other indicators should be tied to the specific action or supplier they relate to, so the reader can see what was measured, what changed, and what the evidence says about progress.
Why this matters · Connect each measure to the action or supplier it relates to, so the evidence tells a clear story.
A supplier audit found repeated excessive overtime at one site, and the company classifies the issue as serious. The draft mentions one incident, but the team is unsure whether to describe the event as a one-off or as part of a wider pattern, and whether the severity label should be explained.
QWhat should the preparer do when recording incidents linked to supplier labour issues?
Reveal model answer →Hide answer ↑The preparer should state how many incidents were identified, describe the kind of incident involved, and explain how serious the company judged it to be. If the case is part of a wider pattern, that should be made clear in the narrative; if it is a single event, that should also be clear. The point is to give enough context for the reader to understand both the scale and the seriousness of the problem.
Why this matters · Record the count, the nature of the incident, and the seriousness judgement with enough context to avoid ambiguity.
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 use the S2-3 page to prepare a disclosure on workers in the value chain?+−
Start with the plain-language explainer and the step-by-step preparation section, then use the listed datapoints to shape your draft. The page is designed to help you organise scope, evidence and ownership before you write the disclosure.
Which S2-3 datapoints should I collect first for workers in the value chain?+−
The page lists the datapoints to prepare, including implemented actions, supplier engagement, audit activity, training and support, impact category, response actions and the incident-related measures. Use that list to decide what data you already hold and what still needs to be requested from owners or suppliers.
How do I decide who owns the S2-3 data collection and drafting work?+−
Use the page as a coordination tool: it points you to the datapoints, the step-by-step preparation process and the evidence pack so you can assign each item to the right business owner. In practice, that usually means separating content owners, data owners and the person assembling the draft.
What should I include in the evidence pack for S2-3 assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those materials to build a file that shows the claim, the risk it addresses and the evidence you can produce.
What are the six assurance claims I need to check for S2-3?+−
The page says there are six assurance claims to verify, each linked to a claim, risk and evidence check. Use that section to test whether your draft is supported by traceable records before it goes to review.
How do I avoid common mistakes when reporting S2-3?+−
The page lists common reporting gaps and mistakes so you can check for missing datapoints, weak evidence or unclear scope before finalising the draft. It is best used as a pre-submission quality check rather than as a substitute for your own controls.
How do I use the S2-3 workbook download to build the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise the datapoints, evidence and assurance checks, and the PDF as a quick reference while drafting.
What can I learn from the synthetic example disclosure for S2-3?+−
The page includes synthetic illustrative examples and a quantitative table to show how the disclosure can be turned into a draft. Treat them as formatting and content examples only, not as real-world benchmarks or required wording.
How do I turn S2-3 data into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line to help you convert your data into report-ready text. Use those prompts to keep the narrative tied to the datapoints and evidence you have collected.
Where can I find real company report examples for S2-3 workers in the value chain?+−
The page has a 'From company reports' table that links to published reports where the topic is disclosed. Use it to see how others present the topic, but keep your own draft grounded in your organisation’s data and evidence.
More questions this page can help with
S2-3 workers in the value chain: what data points should I ask suppliers and internal owners for?S2-3 disclosure: how do I build an assurance-ready evidence pack from the page?How should I use the S2-3 step-by-step preparation section to scope the disclosure?What are the common S2-3 reporting gaps I should check before sign-off?How do I use the Prep & Assurance workbook for S2-3 workers in the value chain?What does the S2-3 synthetic example disclosure show me about drafting?How do I assign ownership for S2-3 implemented actions, audit activity and incident data?What should an assurance reviewer look for in an S2-3 draft?How do I convert S2-3 supplier engagement and training data into narrative text?Where are the S2-3 visualisation ideas and narrative starters on the page?
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