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GRI 2: General Disclosures
Disclosure GRI 2-14

Role of the highest governance body in sustainability reporting

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 you to explain how the organisation’s highest governance body is involved in sustainability reporting. In practice, that means describing what role it plays in overseeing the report, reviewing the information before publication, and being accountable for the way sustainability matters are presented. The focus is on governance involvement, not on repeating the report content itself.

The practical question is whether this oversight covers the organisation as a whole, rather than only selected business units or flagship sites. You should make clear how the top governing body engages with reporting across operations, how far its oversight reaches, and whether it has a direct role in approving or challenging the information reported.

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
Board approval process State whether the board or equivalent top governing group reviews and signs off the reported content, including the topics the organisation has judged most important. If it does, describe the review and approval steps in plain terms. Board papers, approval minutes, governance calendar, sign-off memo, reporting controls log. Company secretariat / Governance
No board sign-off reason If the board or equivalent top governing group does not review and approve the reported content, including the organisation’s key topics, explain why that is the case. Governance policy, delegated authority matrix, board charter, reporting approval workflow, committee terms of reference. Company secretariat / Governance
＋ Show GRI 2-14 sub-elements (LRA working checklist)

How to prepare it

1Confirm which governing group sits at the top of the organisation, and decide whether it is the body that signs off the reported information and the topics judged most important.
2Set the scope of the check clearly: identify the report content that needs review, including the important topics covered, so you know exactly what the approval process applies to.
3Gather proof of how the review and sign-off happened, or would happen, such as meeting records, approval notes, or internal sign-off trails that show the process used.
4Prepare the disclosure text in plain language: state whether that top governing group is responsible for review and approval, and describe the process if it is.
5If that group does not carry out the review and approval role, write a clear explanation of why another arrangement is used instead.
6Check the final wording against the official source to make sure the answer covers both required cases, matches the evidence, and does not add or omit anything.
Request the data

Request board sign-off and review trail for sustainability reporting

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

Did the board or its committees review and approve the sustainability report content, including the material topics, and if not, why was that responsibility handled elsewhere?

Use your organisation’s own names for the board, committees, report pack and approval steps first, then map them to the reporting disclosure. This is a possible LRA training template to adapt to your organisation; check the official source before sign-off.

Weak request

Please confirm the governance body’s role in sustainability reporting and provide the process for reviewing and approving the information.

Why it fails: It uses framework language that may not match how the organisation works, and it does not ask for the actual evidence trail, dates, version, forum, or the reason where the board was not the decision-maker.

Better request

Please send the board or committee papers, minutes, approval note, and version history for [reporting period] showing whether the board or a committee reviewed and approved [report name], including the material topics list. If that was not done at board level, please explain why and point us to the management or committee route used.

Formal email template
Subject: Request for board review and approval evidence for sustainability reporting

Dear [Name],

We are preparing the sustainability reporting evidence pack and need your help with the board-side review trail for [reporting period].

Please send the following for [report / report section name]:
- whether the board or one of its committees reviewed and approved the content, including the material topics list;
- if yes, a short description of how the review and approval happened;
- if no, the reason this was handled outside the board or committee route;
- supporting evidence such as papers, minutes, approval notes, or decision logs.

Please include the relevant dates, the forum involved, and the version of the report reviewed.

This is a possible LRA training template to adapt to your organisation. Please check the official source before sign-off.

Kind regards,
[Your name]
[Team / function]
Short Teams / Slack version
Hi [Name] — could you share the board / committee review trail for [reporting period] for [report name]? We need to know whether the board or a committee reviewed and approved the report content, including the material topics, and if not, why that route wasn’t used. Please attach the minutes / paper / approval note and the date, forum and version reviewed. This is a possible LRA training template to adapt to your organisation; check the official source before sign-off.
Industry examples
Manufacturing

Context. A group sustainability report is signed off through an audit committee before board noting.

Adapted request. Please share the audit committee paper, minutes and approval note for [reporting period] showing whether the committee reviewed and approved the sustainability report and the material topics list, plus any board note or final sign-off record.

Example response. Committee paper dated [date], minutes showing review of climate, workforce and supply chain topics, approval note for v4, and a board paper noting the committee’s approval.

Financial services

Context. The annual report includes a sustainability section reviewed by the risk committee, with final board approval of the full report.

Adapted request. Please provide the risk committee pack, minutes and board approval record for [reporting period] covering the sustainability section and the material topics used in the report, including any explanation if the board did not directly approve that section.

Example response. Risk committee paper and minutes showing review of the sustainability section, board paper approving the annual report, and a note that the committee handled detailed review while the board approved the final report package.

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 whether the board or another governance route was used to review and approve the report, and explain the basis used to decide that approach, including how any material topics were handled.

Context note

This tells readers who stood behind the final reported information and whether oversight covered the organisation’s key issues as well as the wider report.

Fluctuation statement

If the review route changed from the prior period, explain what drove the change, such as a shift in governance responsibilities, reporting scope or approval practice.

Content index entry
GRI 2-14 Role of the highest governance body in sustainability reporting — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 2-14 — 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 ↧
Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
The information reported for this disclosure reconciles to the underlying source records.What is reported cannot be traced back to the systems or documents it was drawn from, or does not tie out to them.calculation_workbook reconciling the reported value to source_system_export
The information reported for this disclosure is current as at the reporting date.The disclosure reflects a different period, a cut-off before the reporting date, or stale data carried over from a prior period.approval_record showing the data cut-off date and the period covered
The scope behind the information reported for this disclosure is applied consistently.Parts of the organisation are silently in or out of scope, or the scope differs from the prior period without that change being explained.methodology defining the scope and a site_register of what it covers
Everything in scope is included in the information reported for this disclosure — nothing material is left out.Parts of the population that should be reported are omitted, understating or overstating the disclosure.site_register of the full population vs the calculation_workbook of what was actually included

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

Asked the wrong owner
Teams sometimes ask the sustainability lead for a board-level answer, when the real source sits with the company secretary, board support team, or the committee that handles report sign-off.
Used framework language instead of business terms
The request goes out in reporting jargon, so the recipient cannot map it to the organisation’s own approval process, committee names, or internal sign-off steps.
Did not define the scope
People collect a generic answer without stating whether it covers the full report, only the material topics section, or just the parts that the board actually reviews.
Mixed up the reporting period
The data pull uses the wrong cycle or meeting window, so the answer reflects a different reporting year than the one being disclosed.
Blended different counting bases
One source counts every meeting, another counts only formal approvals, and the final pack merges them as if they were the same measure.
Lost the source labels
Original file names, meeting references, version tags, or committee labels are stripped out, making it hard to trace which document supported the answer.
Combined separate groups
Responses for the board, its committees, and other governance groups are merged into one bucket even though they should be kept distinct for the disclosure.
Missed the evidence trail
The team captures the answer but not the supporting note, email, agenda, or minutes reference, so there is no clear audit path back to the source.
No sign-off record
The draft answer is circulated informally and never gets a dated approval from the person who owns the governance process, leaving no proof of who confirmed it.

Where judgement is often needed

Board sign-off sits with a committee, not the full board
If a committee or other sub-group does the detailed review, state whether the board itself still gives final sign-off or whether the committee’s approval is the organisation’s chosen control point, and describe that route clearly.
Approval happens only for some reporting content
Where the board reviews the report but not every topic or annex in the same way, explain which parts it sees, which parts are handled elsewhere, and how you decided what counts as board-level approval.
A new acquisition or disposal changes the reporting perimeter
If the group structure changed during the period, explain whether the board reviewed the report on the old or updated perimeter, and note any cut-off date or transition rule used to keep the narrative consistent.
Different country teams use different local labels for the same oversight role
When governance titles or approval routes vary across jurisdictions, map the local process into your own operating language and disclose which entity or forum you treated as the approving body for the report.
The board reviews the report after year-end but before publication
If the review and approval happen after the reporting period has closed, state the timing you used and make clear whether the board approved the final report version or only an earlier draft.
Some material topics are still being finalised when the board reviews the report
If a few topics are based on estimates, late inputs, or draft analysis at the time of review, say so and explain how the board was able to approve the information despite those open points.
Population at the edge of scope is included or excluded by judgement
Where a business unit, site, or joint arrangement sits near the boundary of what you report, explain the inclusion or exclusion choice and how that affected what the board saw before approval.
Privacy rules mean the board sees grouped rather than person-level information
If sensitive information is aggregated before it reaches the board, describe the level of summarisation used and confirm that the board reviewed the same grouped version that appears in the report.
The board’s review relies on estimates rather than direct measurement
When the approval pack uses estimates, proxies, or sampled data, disclose the basis for those figures and note any material areas where the board relied on management judgement rather than measured results.
Rounding or presentation choices change the appearance of the approved figures
If rounding, percentage presentation, or table formatting affects the numbers the board sees, explain the convention used so readers can understand that the approved version matches the published one.
Examples

Illustrative examples

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

Illustrative (synthetic) example — Food processing

*Synthetic example:* Our board signs off the report after management has completed the draft and the material issues summary. The sustainability team prepares the pack, the audit committee checks the figures and wording, and the board gives final approval before publication. - We use this route because the board is directly involved in reviewing the report and the topics we have judged to be most important. - The review covers both the narrative and the material issues list, with any changes tracked through a final sign-off note.

This example shows a reporter where the board takes responsibility for review and approval, including the material topics, and describes a simple approval chain.

Illustrative (synthetic) example — Specialist logistics

*Synthetic example:* Our executive sustainability forum, not the board, reviews and approves the report and the material issues summary. We follow this approach because the board has delegated day-to-day sustainability oversight to that forum, while still receiving a brief update after publication. - The forum checks the draft, challenges the material issues list, and authorises release once the finance and legal leads confirm the final version. - The board is informed afterwards, but it does not carry out the approval step itself.

This example shows a reporter where the board is not the approving body, and explains that the reason is delegation to another internal group.

Company reports

How companies report GRI 2-14

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

Interconexión Eléctrica S.A. E.S.P.
Electric Utilities / IPP / Energy Traders · Colombia · 2024
Open report →
Interconexión Eléctrica S.A. E.S.P.'s 2024 Integrated Management Report includes coverage of the process for determining material topics, with a specific description found on page 143. The report also references the review and approval of information related to material topics by governance bodies on pages 135 and 136. However, there is no clear or quotable evidence regarding the methodology or narrative for item (a), indicating some aspects of the disclosure remain unclear.
Rhenus Group
Ground Transportation — Trucking · Germany · 2024
Open report →
Rhenus Group's 2024 Sustainability Report includes a covered datapoint on the role of the highest governance body in overseeing the management of impacts, specifically noted on page 49. The report references material topics and the GRI content index across multiple pages (15, 26, 41, 42, 52), indicating attention to sustainability issues, but no clear narrative or methodology explanation for item (a) was found. Overall, the report provides some governance-related information but lacks explicit narrative detail for certain disclosure elements.
Thai Beverage Public Company Limited
Food and Beverage Processing · Thailand · 2024
Open report →
Thai Beverage Public Company Limited’s Sustainability Report 2024 includes reported values related to economic performance on page 180 and information about the highest governance body on page 182. The report also references management of material topics and governance and business ethics across pages 186, 187, 190, and 3, indicating coverage of economic and governance disclosures. However, the specific details of these values and governance roles are not clearly presented in the extracts, limiting clarity on the full extent of disclosure.
✓ LRA AI Assistant · Human-in-the-loop
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Check your understanding

Scenarios to work through

The reporting team has drafted the sustainability section and the board papers show that directors review the draft before it is signed off. The same papers also show the board checks the list of topics judged most important to the organisation.

QShould the disclosure say that the board reviews and approves the reported information, and should it describe how that review and approval happens?
Reveal model answer →

A company’s sustainability report is approved by an audit committee, while the full board only receives a summary after publication. The material topic list is prepared by management and never goes to the board for sign-off.

QHow should the disclosure be framed when the board itself does not review or approve the report content or the material topic list?
Reveal model answer →

The board approves the annual report as a whole, but sustainability content is checked only by management and an external writer. There is no board discussion of the material topic assessment, although the board does approve the final report pack.

QDoes a general board sign-off on the report pack on its own answer the disclosure, or is more detail needed?
Reveal model answer →

A group has a sustainability steering committee that prepares the content, but the board only receives the final draft for information and does not approve it. The team is unsure whether to mention the committee or focus only on the board.

QWhat should the preparer disclose about governance involvement in the reporting process?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 2-14
within GRI 2: General Disclosures
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

For GRI 2-14, what should I gather before drafting the disclosure if I need to explain the board approval process or why there was no board sign-off?+
How do I use the step-by-step 'how to prepare' section for GRI 2-14 in practice?+
What evidence should I keep for GRI 2-14 if I want the disclosure to be assurance-ready?+
What are the four assurance claims on the GRI 2-14 page and how do I use them?+
What common mistakes does the GRI 2-14 page warn about when reporting board approval process information?+
How should I assign ownership for the GRI 2-14 disclosure between ESG, HR, data owners and the company secretary or board team?+
Can I use the GRI 2-14 workbook to build the disclosure from scratch?+
What is the printable Library Card for GRI 2-14 and when would I use it?+
Does the GRI 2-14 page include an example disclosure I can copy into my draft?+
How do I turn the GRI 2-14 page content into a draft disclosure and content-index line?+
More questions this page can help with