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GRI 101: Biodiversity · 2024
Disclosure GRI 101-3

Access and benefit-sharing

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 GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how it approaches access and benefit-sharing where it uses biological resources or related traditional knowledge. In practice, the report should make clear whether the organisation has identified relevant activities, what policies or processes it uses, and how it manages permissions, agreements, and any sharing of benefits that may arise.

The practical focus is on the organisation’s real-world coverage, not just a single flagship site or one-off project. Readers should be able to see whether the approach applies across the business, which parts of the organisation are in scope, and how consistently the organisation applies its process where access and benefit-sharing issues are relevant. This is educational guidance only and should be checked against the applicable reporting requirements.

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

Before you start

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

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Compliance process Capture a plain description of the steps the organisation uses to meet access and benefit-sharing rules and related measures, including how those steps are applied in practice. Policy or procedure notes, compliance workflow, legal review records, and any internal controls or checklists used to manage access and benefit-sharing obligations. Legal / Compliance
Voluntary biodiversity actions Capture a plain description of any voluntary actions the organisation has taken to support access and benefit-sharing beyond what the law requires, including action taken where no relevant rules or measures exist. Project notes, programme descriptions, partnership records, board or management approvals, and other internal evidence showing the voluntary nature of the actions. Sustainability / ESG
+ Show GRI 101-3 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which parts of the business, sites, activities, and value-chain relationships are in scope for this disclosure, so the same boundary is used consistently when gathering the two required descriptions.
2Separate the two content streams early: one for how the organisation manages compliance with access-and-benefit-sharing rules and measures, and another for any voluntary actions that go beyond legal duties or apply where no such rules and measures exist.
3Define what will count as evidence for each stream: collect internal policies, procedures, approvals, records, and other source material that supports the process description and the voluntary-action description, rather than relying on unsupported narrative.
4Draft the compliance-process account in plain language: explain the practical steps the organisation uses to meet the relevant rules and measures, using the evidence to show how the process works in practice.
5Draft the voluntary-actions account separately: describe the extra steps taken beyond legal requirements, or the actions used where no applicable rules and measures are in place, and make clear that these are additional measures rather than compliance controls.
6Check the final wording against the official source and your evidence pack: confirm both descriptions are complete, any exclusions or scope changes are explained, and the published text matches the underlying records without adding unsupported claims.
Request the data

Request the access-and-sharing evidence from Legal / Compliance

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

What evidence can we use to explain how the organisation manages access-and-sharing obligations, and what extra steps it takes where it goes beyond the legal baseline or where no local rules apply?

Use your organisation’s own terms first, then map them to the disclosure. For example, if your teams talk about permits, permits-to-work, biodiversity approvals, local community agreements, or resource-use permissions, use those labels in the request and response. Keep the ask in business language, and only translate into the reporting wording at the end. Check the official source before sign-off.

Weak request

Can you send the GRI 101-3 evidence for access and benefit-sharing?

Why it fails: It uses framework language only, so the owner may not know which internal process, documents, or locations to pull together. It also does not ask for the practical details needed to explain how the process works or what extra actions are taken where the baseline is limited.

Better request

Can you send the documents and a short summary showing how we manage permissions, approvals, and any related sharing commitments in [site/jurisdiction] for [reporting period], plus any extra steps we take where local rules are thin or where we choose to go further? Please include the source, coverage, and any exclusions, using your team’s own terms.

Formal email template
Subject: Request for access-and-sharing evidence for [reporting period]

Hi [name/team],

I’m pulling together the sustainability reporting pack for [reporting period] and need your help with the material on how we manage permissions, approvals, and any related sharing or local benefit commitments.

Please send:
- A short plain-English summary of the process we use to stay aligned with the relevant rules and controls in [jurisdiction/site/project]
- Any supporting documents that show how this is handled in practice (for example, procedures, registers, approvals, or governance papers)
- Any examples of extra steps we take where local rules are limited or where we choose to do more than the minimum
- The period covered, the business area/site covered, and the source of the information
- Any gaps, exclusions, or caveats we should note

Please use your team’s own terminology in the response, and I’ll map it into the reporting wording afterwards. If helpful, I can turn your notes into a short draft for you to review.

Please send this by [date]. Check the official source before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — could you send over the access-and-sharing evidence for [reporting period]?

I need a short summary of how we handle permissions/approvals and any extra steps we take beyond the baseline, plus any supporting docs, the period covered, and any gaps/exclusions.

Please use your own team terms — I’ll map them for reporting. Check the official source before sign-off. Thanks.
Industry examples
Mining / Extractives

Context. A site team manages land access, exploration permissions, and community agreements across several jurisdictions.

Adapted request. Please send the site-level summary and supporting records showing how we handle exploration permissions, land-use approvals, and any community-sharing commitments for [reporting period], including any extra measures we take where local rules do not cover the issue in full.

Example response. The site provided a permit register, a compliance procedure, and a community agreement log. It also noted a voluntary local training and grievance follow-up process used at two sites where the legal framework did not set out a detailed engagement process.

Pharmaceuticals / Life sciences

Context. R&D teams use biological samples and external research materials under contract terms and local permissions.

Adapted request. Please send the summary and evidence showing how we manage permissions, contract terms, and any additional stewardship steps for [reporting period] across R&D and sourcing, including where we apply extra controls beyond the local baseline.

Example response. The team returned a materials approval procedure, supplier contract clauses, and a register of sample-use approvals. It also described a voluntary review step for new collaborations in locations with limited local guidance.

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

We describe the basis used to compile the disclosure, including how we defined compliance checks and what we counted as additional voluntary action.

Context note

The figures and descriptions show how the organisation manages access-and-benefit-sharing in practice, both where formal rules apply and where it has chosen to go further.

Fluctuation statement

If the approach changed during the period, explain whether that was due to new legal requirements, changes in operating locations, or a shift in voluntary practice.

Content index entry
GRI 101-3 Access and benefit-sharing — [location / page] / [notes]
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Preparation tools & forms

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We documented the steps we used to check that the disclosed process aligns with the relevant access-and-sharing rules, including how we identified the applicable rules and who reviewed the conclusion.The assurer will test whether the process was actually followed, whether the right rules were identified for each case, and whether the review was independent and complete.Procedure note or methodology paper; legal/regulatory mapping; review sign-off; internal emails or meeting notes showing the assessment; version history of the working papers; any gap log or issue tracker.
Where we went beyond legal duties, or where no specific rules applied, we recorded the extra actions we took and the basis for saying they were voluntary rather than mandatory.The assurer will probe whether the reported actions were genuinely additional, whether the boundary between required and voluntary was applied consistently, and whether any omissions were justified.List of voluntary measures; rationale memo for each measure; legal analysis showing the absence of a rule or the minimum required position; approvals from the responsible team; supporting project records, plans or implementation evidence.
We kept evidence showing how the coverage figure was built, including the source data, the scope choices we made, and the checks we carried out before publication.The assurer will look for completeness of the population covered, consistency of scope decisions, and whether the figure can be traced back to reliable source records without unexplained adjustments.Source datasets; scope boundary notes; calculation workbook; reconciliation to underlying records; data owner confirmations; pre-publication review checklist; change log for any manual edits or exclusions.
Before release, we ran internal quality checks on the disclosed information and resolved any anomalies we found, so the final version matched the approved working papers.The assurer will test whether the final disclosure agrees with the approved numbers and narrative, whether exceptions were investigated, and whether the review was strong enough to catch material errors.Final approval pack; quality-control checklist; exception log and resolution notes; sign-off from preparer and reviewer; comparison between draft and published version; evidence of corrections made before issue.

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 team chases Legal or Sustainability for the answer when the real source sits with the function that handles permits, fieldwork, sourcing, or local partner agreements.
Framework language only
People ask for information using disclosure jargon, so the business cannot map the request to its own controls, records, and day-to-day process names.
Scope left vague
The data pull starts before anyone has fixed which sites, projects, suppliers, or countries are in scope, so the result mixes unrelated activity.
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Where judgement is often needed

What counts as the group you are reporting on after a buy-in or sale
Set a clear cut-off for acquisitions and disposals, explain which entities or activities are included for the period, and note any change in scope so readers can see why the process description moved.
When local rules use different terms or tests
If country-level rules describe access permissions or benefit-sharing differently, explain the local rule set you followed in each place and how you translated that into one group-wide description.
How to handle sites, projects, or teams that sit partly inside the scope
State the rule you used for borderline cases, such as including only operations with a direct link to the relevant activity, and disclose any exclusions that were made on that basis.
+ Show 5 more
Examples

Illustrative examples

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

Illustrative (synthetic) example — Food ingredients and agriculture

We run a supplier and site review each year to check that any land, genetic resource, or traditional-knowledge use linked to our operations has the right permissions, benefit-sharing terms, and recordkeeping in place. - Our compliance check starts with a legal register, contract review, and sign-off from procurement, legal, and sustainability teams before any project can proceed. - In the year, 18 of 18 relevant projects were reviewed; 18 were cleared, 0 were escalated, and 100% had documented evidence of the permissions and benefit-sharing terms needed. - Beyond what the law requires, we also support local partners through training, shared field data, and two community research agreements, even where no specific rule applies.

This example shows how to describe the control process and then separate out extra voluntary actions, while keeping the figures internally consistent.

Illustrative (synthetic) example — Pharmaceuticals and biotechnology

We use a staged approval process to make sure any access to biological material or associated local knowledge is checked against the relevant rules, with legal review, ethics review, and final approval before use. - During the period, 12 of 12 new material requests went through the full review route; 12 were approved with the required terms attached, 0 were rejected, and 100% were logged in our tracking system. - Where the law does not set a specific rule, we still choose to share outcomes through local workshops, capacity-building support, and one voluntary benefit-sharing arrangement with a research partner. - These extra steps are separate from our compliance checks and are intended to strengthen fair sharing in practice.

This example uses a different sector and a different control path, then adds voluntary measures taken even when no formal rule is in place.

Company reportsReal published reports
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How companies report GRI 101-3

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

Godrej Properties Limited
Real Estate · India · 2025
Open report →
Godrej Properties Limited's Integrated Report 2024-25 includes a specific reported value of "2" on page 211 and details an additional 22.46 percent profit sharing of GVLLP by giving exit to its joint venture partners on page 233. The report also references compliance with occupational health and safety standards and biodiversity impact identification, though these are not clearly linked to the main disclosure datapoints. Notably, the report lacks detailed narrative explanations or contextual information for these values, making some aspects unclear.
Sumitomo Forestry Co., Ltd.
Home Building · Japan · 2025
Open report →
Sumitomo Forestry Co., Ltd.'s Sustainability Report 2025 provides coverage on access and benefit-sharing (ABS) related to biodiversity impacts, with specific references to identification of impacts and locations on page 529. The report also notes on page 131 that there were no particular regions of concern related to genetic resources held by Indigenous peoples. However, the report does not clearly detail the processes or outcomes of ABS agreements, and further specifics on direct benefits or compliance mechanisms remain unclear.
Home Product Center Public Company Limited
Retailing · Thailand · 2025
Open report →
Home Product Center Public Company Limited’s Sustainability Report 2025 covers actions taken related to anti-competitive behavior, referencing specific pages (263-264) and management of material topics (p.200). The report also highlights leadership roles in promoting effective and beneficial practices, with supervisors expected to lead, train, and coach (p.117). However, details on the specific outcomes or metrics related to anti-competitive behavior and compliance with laws such as Thailand’s PDPA are mentioned but not fully detailed or quantified in the provided extracts (p.192).
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Scenarios to work through

A cosmetics business uses a plant extract sourced from a country where biodiversity rules apply. The sustainability team has a written process for checking permits, contract terms, and local conditions before any new sourcing deal is approved.

QShould the disclosure explain that process, and what level of detail is useful for a reader?
Reveal model answer →

A food company buys a seed ingredient from a supplier in a place where there are no access-and-sharing rules in force. The company still has a contract clause asking the supplier to share benefits if local rules appear later.

QDoes this belong in the part of the disclosure about extra actions beyond legal duties or where no rules exist?
Reveal model answer →

A biotech firm has two sourcing routes for the same material. One route is covered by local access-and-sharing rules and the other is not. The reporting team has one paragraph that mixes both routes together without saying which controls apply to which.

QHow should the disclosure be handled so a reader can tell the difference?
Reveal model answer →

A personal-care company has no direct ownership of the plant material it uses, but it does approve suppliers and sets sourcing conditions. The team is unsure whether the narrative should focus only on the supplier’s obligations or also on the company’s own checks and follow-up.

QWhat should the disclosure emphasise in this situation?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 101-3
within GRI 101: Biodiversity
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

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