Disclosure focus
This disclosure asks an organisation to explain how it identifies, manages and reports conflicts of interest that could affect decision-making, judgement or trust. In practice, it is about showing whether there are clear rules and processes for spotting actual, potential and perceived conflicts, and how those are handled across the organisation rather than only in a few visible parts of the business.
The practical focus is on coverage and consistency: the explanation should show whether the approach applies to the whole organisation, including governance bodies and relevant staff, and how it works in day-to-day operations. It should also make clear what happens when a conflict is identified, such as disclosure, recusal, review or other controls, so readers can see that the organisation is managing the issue in a systematic way.
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
＋ Show GRI 2-15 sub-elements (LRA working checklist)
Set out how the board prevents and reduces conflicts of interest.
State whether conflicts are shared with stakeholders, including any overlap in board membership.
State whether conflicts are shared with stakeholders, including any supplier or other stakeholder cross-holdings.
State whether conflicts are shared with stakeholders, including where a controlling shareholder exists.
State whether conflicts are shared with stakeholders, including connected parties, their links, transactions, and any unpaid balances.
How to prepare it
1Set the reporting boundary first: identify which governance-level processes you are describing, and make sure the write-up covers how the top decision-making group handles conflicts of interest in practice.
2Map the prevention and mitigation controls: gather the policies, approval routes, declarations, recusal rules, monitoring checks, and escalation steps that show how conflicts are stopped or reduced before they affect decisions.
3Decide what counts as a conflict for this disclosure: include the four stakeholder-linked areas named in the source — board overlap, supplier or other stakeholder shareholdings, a controlling owner, and related-party links, dealings, and unpaid amounts.
4Collect the supporting evidence and turn it into a clear statement on disclosure: confirm whether these conflicts are shared with stakeholders, and note the relevant channels, reports, registers, or governance papers that support that answer.
5Draft the disclosure with both narrative and, where relevant, factual detail: explain the process in plain language, then state the disclosure position for each of the listed conflict areas without adding extra categories or omitting any of them.
6Record any exclusions, changes, or limitations, then check the final wording against the official source to make sure the meaning is complete, the scope is consistent, and nothing has been added, removed, or misstated.
Request the data
Request board conflict-of-interest evidence and stakeholder disclosure details
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do we prevent and manage board-level conflicts, and what conflict-related matters are shared with external stakeholders?
Use your organisation’s own terms first, then map them to the reporting disclosure. For example, you may talk about director declarations, board registers, related-party papers, shareholder disclosures, or governance notices rather than using framework language in the request.
Weak request
Can you confirm whether the organisation has conflicts of interest disclosures and whether the highest governance body has processes to prevent and mitigate them?
Why it fails: This uses framework wording and asks for a yes/no answer without pointing to the actual records the owner controls. It does not say which board papers, registers, related-party schedules, or external disclosures should be pulled, so the response is likely to be incomplete or hard to verify.
Better request
Please send the board conflict register, director interest declarations, related-party schedule, and any annual report or website wording for [period] covering [entity]. We need the material that shows how the board handles declarations, review, escalation, and follow-up for possible conflicts, and any external disclosure about board overlaps, supplier ownership links, controlling shareholders, and related-party relationships, transactions, and balances. Please include source, date, owner, and coverage, and flag any gaps.
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 organisation defines a conflict of interest, which governance groups are covered by the review, and what evidence was used to confirm the prevention, mitigation and disclosure arrangements.
Context note
Set out what the figures mean in practice by linking the disclosure approach to how the board manages independence, transparency and trust in decision-making.
Fluctuation statement
If the disclosure pattern changed from the prior period, note whether this was due to new governance arrangements, a broader review of conflict types, or changes in what was shared with stakeholders.
Content index entry
GRI 2-15 Conflicts of interest — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 2-15 — 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.
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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 board process, disclosure practice, or related-party records are never pulled together from the people who actually run them.
Framework language only
The data call uses GRI-style labels instead of the organisation’s own terms, and the people answering cannot map the request to their registers, approvals, or reporting packs.
Scope not fixed
The team does not define which board members, committees, subsidiaries, or business units are in scope, so the data set ends up incomplete or too broad.
Wrong reporting period
The collection window is left vague, so some teams send current-year information while others send opening balances, year-end positions, or a different cut-off date.
Mixed counting basis
One source reports individual cases while another reports entities, transactions, or balances, and the results are merged as if they were the same measure.
Source labels lost
Original tags from the register, board paper, or finance schedule are stripped out, making it impossible to trace each item back to the underlying record.
Separate populations merged
Cross-board links, supplier holdings, controlling owners, and related-party items are lumped into one file even though they need to stay distinct for review.
Evidence trail missing
The pack contains figures or statements but no note of where they came from, who checked them, or when the source was last updated.
No sign-off record
The draft data is circulated without a clear approval trail, so nobody can show who reviewed the inputs before the disclosure text was written.
Where judgement is often needed
What counts as the group that oversees conflict controls
Decide whether to describe the board alone or the board plus its committees, and explain the practical checks each part uses to stop and reduce conflicts.
How to handle board links that sit across more than one entity
If a director serves on another board, state how you judge that link as a conflict and whether you tell external audiences about it.
Whether supplier shareholdings are material enough to mention
Set a clear threshold for when an ownership stake in a supplier or other business partner is treated as relevant, and disclose the basis for that cut-off.
How to treat a controlling owner with indirect influence
Explain whether you look only at direct control or also at indirect routes of influence, and say how that choice affects what you tell stakeholders.
Which related-party links and balances are included
Define the relationships, transactions and unpaid amounts you include, and note any exclusions where the connection is too remote or immaterial to report separately.
How to deal with entities entering or leaving the group during the year
State whether you report conflicts and related links using the year-end group, the average group, or another cut-off date, and explain how acquisitions or disposals change the scope.
How to apply local definitions across different countries
Where local law or market practice uses different labels or tests, explain the rule you used to align those cases so the same type of conflict is treated consistently.
When to use estimates, aggregation or rounding
If exact figures would expose personal or commercial details, say when you group items, round amounts, or use estimates, and make clear that the method is applied consistently.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Consumer goods manufacturing
We use a formal conflicts register, annual declarations, and pre-approval checks for outside interests so the board and its committees can spot, stop, and manage any issue before it affects decisions. In this synthetic example, 12 of 12 directors and 18 of 18 committee members filed declarations on time, and 3 potential conflicts were escalated, with 2 resolved through recusal and 1 through removal from the decision process. - We also make selected conflict information available to stakeholders in our governance report, including links created by shared board membership, cross-holdings with suppliers and other counterparties, the presence of a controlling shareholder, and related-party relationships, transactions, and balances. - For this illustrative disclosure, 4 of 4 identified related-party arrangements were reported, and 2 of 2 material outstanding balances were shown in the notes; no unreported material conflicts were identified at period end.
Synthetic illustration only. Shows how a reporter might describe board-level controls and external disclosure of different conflict types without using the standard’s wording.
Illustrative (synthetic) example — Infrastructure services
Our board requires annual declarations, meeting-by-meeting checks, and a documented escalation route so any personal or commercial conflict is identified early and handled before it can influence oversight. In this synthetic example, 9 of 9 directors completed declarations, 6 of 6 audit committee members confirmed no new issues at the latest review, and 2 matters were managed by abstention while 1 was referred for independent review. - We tell stakeholders about relevant conflict matters in our annual report, covering overlapping board roles, share links with suppliers and other stakeholders, the existence of a controlling owner, and dealings with related parties, including the relationships involved, transactions made, and balances still open. - In this illustrative case, 5 of 5 reportable related-party transactions were disclosed, alongside 3 of 3 outstanding balances; the same report also explained that no undisclosed cross-board or shareholding conflicts were found during the year.
Synthetic illustration only. Demonstrates a second plausible reporting style with different figures and a different sector, while covering the same disclosure points.
Company reports
How companies report GRI 2-15
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
Interconexión Eléctrica S.A. E.S.P.'s 2024 Integrated Management Report provides partial information on the policy and practice of requesting external verification, mentioning this context on page 131 without specifying a headline value. There is no evidence found regarding the involvement of the highest governance body or other detailed narrative items related to this disclosure. Overall, the report offers limited coverage, with several key aspects notably missing or unclear.
Thai Beverage Public Company Limited
Food and Beverage Processing · Thailand · 2024
Thai Beverage Public Company Limited’s Sustainability Report 2024 provides coverage on the role of the highest governance body, including a reference to the Chair of this body on page 182. The report also details stakeholder engagement processes, with management interviews used to capture stakeholder perspectives as noted on page 180. However, there is no available evidence in the report regarding narrative items (b-ii), (b-iii), and (b-iv), indicating these aspects are not addressed or are unclear.
Sumitomo Forestry Co., Ltd.
Home Building · Japan · 2025
Sumitomo Forestry Co., Ltd.’s Sustainability Report 2025 includes coverage of governance aspects related to sustainability, such as the highest governance body’s role and conflicts of interest (p.528), as well as data on the proportion of senior management hired from the local community (p.530). The report also addresses corporate governance policies on cross-shareholding and standards for concurrent board positions (pp.456, 449). However, there is no evidence found for narrative item (b-iv), indicating a gap in coverage for that specific disclosure element.
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Check your understanding
Scenarios to work through
A board member has joined a committee at another organisation that also does business with your organisation. The governance team is drafting the annual report and has a note that this outside role could affect how decisions are seen.
QShould this outside board role be treated as a conflict that is explained to stakeholders, and how should the team decide what to include?
Reveal model answer →Hide answer ↑Yes. The team should assess whether the overlapping role could create, or appear to create, a conflict, then explain it in plain language to stakeholders if it is relevant. The disclosure should cover the fact of the overlap and enough context for readers to understand the issue, using wording adapted to the organisation’s own circumstances and checked against the source before sign-off.
Why this matters · When a person sits on more than one board or committee, the overlap may need to be explained if it could affect independence or judgement.
Your organisation owns a minority stake in a supplier, and that supplier also has a small shareholding in your organisation through an investment vehicle. The reporting team is unsure whether this cross-ownership belongs in the governance section or can be left out because the amounts are small.
QDo you need to consider this cross-ownership when deciding what conflict information to share with stakeholders?
Reveal model answer →Hide answer ↑Yes. Even if the holdings are small, the team should consider whether the mutual ownership could create a conflict or the perception of one, and then decide whether to disclose it to stakeholders. The explanation should be clear, factual, and tailored to the organisation’s situation rather than copied from the source.
Why this matters · Shared ownership with suppliers or other counterparties can be relevant even when the stake is not large.
A family trust controls 62% of the voting rights in your organisation, and several directors are related to the trust’s beneficiaries. The draft report mentions the ownership structure but says nothing about possible conflicts because the trust is already named elsewhere in the report.
QIs it enough to mention the ownership structure, or should the team think about conflict disclosure as well?
Reveal model answer →Hide answer ↑The team should think about conflict disclosure as well. Where one party has controlling influence, the report should consider whether that creates a conflict issue that stakeholders ought to know about, and explain it in a way that helps readers understand the governance implications. The ownership fact alone may not be enough if the conflict angle is material to the audience.
Why this matters · A dominant owner can create a conflict question that needs separate, plain-language explanation.
Two senior managers are related to a company that provides key services, and one of those managers also sits on the procurement review panel. The finance team has recorded the relationship internally, but the external report currently only lists the supplier name and contract value.
QShould the report go beyond the contract details and explain the related-party link and any balances or transactions that matter to stakeholders?
Reveal model answer →Hide answer ↑Yes. If the relationship could affect, or be seen to affect, decisions, the report should explain the related-party connection in stakeholder-facing language and include the relevant relationships, transactions, and any outstanding amounts that are important for understanding the conflict. The wording should be adapted to the organisation and checked against the source before publication.
Why this matters · Where related parties are involved, stakeholders may need the relationship, dealings, and any unpaid amounts to understand the conflict properly.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Organizational details → Guide ✓Nomination and selection of the highest governance body → Guide ✓Chair of the highest governance body → Guide ✓Role of the highest governance body in overseeing the management of impacts → Guide ✓Delegation of responsibility for managing impacts → Guide ✓Role of the highest governance body in sustainability reporting → Guide ✓Show all 29 related disclosures →
FAQ
Questions this page answers
For GRI 2-15, what data do I need to gather before I start drafting the disclosure?+−
The page says to prepare five datapoints: conflict controls, cross-board conflicts, supplier shareholdings, controlling owners, and related-party dealings. Use those as the starting checklist before you draft anything.
How do I use the step-by-step 'how to prepare' section for GRI 2-15?+−
Use it as a practical workflow to move from scoping and data collection to drafting and checking the disclosure. The page is designed to help you prepare the disclosure in a structured way rather than leaving it as a last-minute write-up.
Who should own the GRI 2-15 data collection in practice?+−
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source and explain the underlying records. The key is to assign clear responsibility for each datapoint and the evidence behind it.
What should I include in the evidence pack for GRI 2-15 assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness. Build it around the source records and supporting documents for the five datapoints, so a reviewer can trace the draft back to evidence.
What are the four assurance claims I need to verify for GRI 2-15?+−
The page says there are four assurance claims to check, each with a claim, risk and evidence angle. Use those claims to test whether the disclosure is complete, supported and consistent with the underlying records.
What are the common reporting gaps or mistakes on GRI 2-15?+−
The page lists common gaps and mistakes to help you avoid weak drafting and missing support. Use that section as a pre-submission check against your data, scope and evidence pack.
How can I use the synthetic illustrative example for GRI 2-15 without copying it blindly?+−
The example is there to show how a disclosure might look, including a quantitative table where relevant. Treat it as a formatting and logic guide only, and make sure your own figures and narrative match your organisation’s actual data.
What should the draft output for GRI 2-15 look like?+−
The page gives draft-output ideas including visualisation options, narrative starters and a GRI content-index line. Use those to turn your checked data into a first-pass disclosure that is easy to review and evidence.
How do I use the Prep & Assurance workbook for GRI 2-15?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, evidence and assurance checks before you finalise the draft.
What is the printable Library Card PDF for GRI 2-15 used for?+−
The Download Centre also includes a printable Library Card in .pdf format. It is a quick reference version of the page content that you can use alongside the workbook during preparation and review.
Does the page give real company examples for GRI 2-15 that I can compare against?+−
Yes, 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 have presented the topic, but keep your own disclosure grounded in your organisation’s data.
More questions this page can help with
What are the five datapoints to prepare for GRI 2-15?How do I scope GRI 2-15 data for a first draft?What evidence should support conflict controls in GRI 2-15?What evidence should support cross-board conflicts in GRI 2-15?What evidence should support supplier shareholdings in GRI 2-15?What evidence should support controlling owners in GRI 2-15?What evidence should support related-party dealings in GRI 2-15?How do I turn the GRI 2-15 workbook into a draft disclosure?What narrative starters are suggested for GRI 2-15?What visualisation ideas are suggested for GRI 2-15?What are the common mistakes to avoid when drafting GRI 2-15?Where can I find real published reports for GRI 2-15 examples?
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