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GRI 202: Market Presence · 2016
Disclosure GRI 202-1

Ratios of standard entry level wage by gender compared to local minimum wage

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 the pay for people starting in standard entry-level roles compares with the local minimum wage, and to do so separately for women and men where relevant. The point is to show whether entry pay sits above, at, or below the legal floor in the places where the organisation operates, rather than to describe pay policy in general terms.

In practice, the focus is on the scope of coverage and the basis of comparison. An organisation should be clear about which operations, countries, sites or employee groups are included, and whether the figures reflect the whole workforce or only selected locations such as flagship sites. If pay differs across locations, the reporting should make that visible so readers can understand the extent of coverage and any variation in entry-level pay relative to local minimum wage.

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
Key operating sites List the sites that matter for this disclosure, using the organisation’s own threshold for what counts as significant and keeping the list aligned to the reporting period. Site register, legal entity map, country/region operating list, and any internal note showing how significance was assessed. Operations / Finance
Gender split Capture the gender categories used for the reported population and the counts or shares attached to each category, using the same classification as the source workforce data. HRIS workforce extract, payroll headcount report, and the organisation’s gender classification guidance or employee self-identification fields. HR / People Analytics
Minimum-wage coverage State whether a material share of employees are paid using rates that sit under minimum-wage rules, based on the employee population in scope for the period. Payroll rates file, wage compliance review, and the employee population extract used for the calculation. Payroll / HR
Entry pay ratio Calculate the starting pay rate against the relevant minimum pay rate and express the result as a percentage, using the same pay basis for both figures. Pay scale or offer-rate schedule, minimum wage reference table, and the calculation workbook showing the numerator and denominator used. Compensation / Payroll
Non-employee coverage Indicate whether a material share of non-employees who help deliver the organisation’s work are paid on rates covered by minimum-wage rules, using the same scope definition throughout. Contractor, agency and outsourced labour records; supplier or labour-provider rate schedules; and the scope note for the worker population. Procurement / HR / Operations
Minimum-pay check method Describe the checks used to confirm that the relevant non-employee group is paid above the minimum level, including the data sources, test steps and any exceptions found. Compliance review memo, payroll or invoice testing, contract rate checks, and exception log. Payroll / Procurement / Compliance
Local wage gap by sex For each significant site, note whether a local minimum wage is missing or changes by gender, and record the position separately for each gender category used. Country wage law summary, local HR policy note, and site-by-site legal review showing whether a single rate or gender-based rates apply. Legal / HR / Country management
Reference wage chosen Name the wage benchmark selected where more than one minimum can be used, and explain which reference was applied for the calculation or comparison. Policy note, legal interpretation memo, and the calculation file showing the chosen benchmark and why it was used. Legal / Payroll / Compensation
Site significance rule Set out the rule used to decide which operating sites are treated as significant, including the threshold, basis of assessment and any exclusions. Disclosure methodology note, internal materiality rule, and the site list reviewed against that rule. Finance / Reporting
＋ Show GRI 202-1 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first. List the sites you will treat as material for this disclosure, and write down your own working definition of what makes a location material so the reader can see how the boundary was chosen.
2Decide which pay groups are in scope. Check whether a material share of employees is paid under wage rates linked to minimum-pay rules, and separately check the same point for other workers who help deliver the organisation’s activities but are not employees.
3Gather the source records before drafting. Pull together payroll, contract, location, and policy evidence that supports the yes/no answers, the wage comparison, and any explanation of how you tested whether pay sits above the floor.
4Prepare the figures and narrative in the required format. Where a ratio is needed, calculate the entry-level pay compared with the relevant minimum and present it as a percentage; where a narrative is needed, explain the approach used to assess non-employee workers and the minimum-pay reference chosen when more than one could apply.
5Record any special conditions clearly. If a local minimum rate is missing or differs across a material site, note that situation and state which benchmark you used, including the gender basis where relevant.
6Review the draft against the source data and the official guidance. Confirm that the scope, definitions, evidence trail, exclusions, and any changes from prior reporting are all consistent, complete, and traceable before sign-off.
Request the data

Request entry pay and minimum-wage comparison data

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

For our significant sites, what is the starting pay level by gender compared with the local minimum wage, and what checks were done where the local benchmark is unclear or varies?

Use your organisation’s own pay and workforce terms first, then map them to the disclosure fields. For example, use your internal labels for sites, worker groups, starter pay, and local wage benchmark rather than framework wording. This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.

Weak request

Please provide the GRI 202-1 data for significant locations of operation, gender, minimum wage references, and the ratio of entry level wage to minimum wage.

Why it fails: It uses framework language only, does not tell the owner what internal records to pull, and leaves out the practical details needed to build the comparison: which sites, which pay basis, which source system, how gender is grouped, and how to handle cases where the local benchmark is not straightforward.

Better request

Please pull the starter-pay review for our key sites for [period]: list the sites covered, the starter pay rate by gender, the local wage benchmark used at each site, and any notes where more than one benchmark could apply or where no clear benchmark exists. Also include any checks done for non-employee workers tied to our activities and a short note on how your team defines the key sites.

Formal email template
Subject: Data request – starter pay and local wage comparison for [reporting period]

Hi [name/team],

We are preparing a sustainability reporting pack and need your help with a pay and wage comparison for our key sites.

Please send:
- the list of significant sites you used for the review;
- starter pay by gender for those sites;
- the local wage benchmark used at each site, including any cases where more than one benchmark could apply;
- whether any sites have no clear local benchmark or more than one possible benchmark, and how that was handled;
- whether any non-employee worker groups tied to our activities were checked, and what was done to confirm they are above the local wage floor;
- a short note explaining how you define the key sites in your team’s process.

Please return the data in a table and include the source system, date extracted, and any assumptions or exceptions.

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

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — could you share the starter pay vs local wage data for our key sites for [period], split by gender, plus any notes on sites where the local benchmark is unclear or varies? Please include the source, assumptions, and how you define the key sites. Thanks.
Industry examples
Retail

Context. Store network with many small sites and a mix of hourly and salaried starters

Adapted request. Please share the starter hourly rate by gender for our main stores and distribution sites in [period], plus the local wage floor used at each site. If a store sits in a place with more than one wage benchmark, note which one you used and why. Also confirm whether any agency or concession staff linked to store operations were checked.

Example response. A table listing each store or depot, country, gender split, starter hourly rate, local wage benchmark, benchmark type, ratio, and a note for any site with more than one possible benchmark.

Hospitality

Context. Hotels and restaurants with tipped and non-tipped starter roles across several cities

Adapted request. Please provide the entry pay review for our hotels and restaurants in [period], split by gender, showing the starter pay used for each site and the local wage benchmark applied. Where city, regional, or age-based wage floors could apply, note which one was selected. Include any review of outsourced or casual staff supporting our operations.

Example response. A site-by-site table with hotel or restaurant name, role family, gender, starter pay basis, local wage benchmark, comparison result, and a short note on benchmark selection and any casual worker checks.

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 you identified the sites treated as major operating locations, which wage benchmark you used where several could apply, and how you checked whether employees and other workers involved in the organisation’s activities were paid above the relevant minimum.

Context note

Set out what the figures mean in practice: they show where minimum-wage rules apply, how entry pay compares with the chosen benchmark, and whether the organisation has any sites where the local minimum is missing or differs by gender.

Fluctuation statement

If the figures changed from the prior period, note whether this was driven by changes in the sites included, the wage benchmark selected, the mix of worker groups covered, or movements in local minimum rates.

Content index entry
GRI 202-1 Ratios of standard entry level wage by gender compared to local minimum wage — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 202-1 — 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
We built the coverage figure from the sites we treat as material to the business, using a documented cut-off and a named reviewer for the final list.The assurer may question whether the site selection was consistent, complete and free from hindsight bias, and whether the final population matches the basis used in the report.['Documented site-selection method and materiality rationale', 'Final site list with approval trail', 'Management sign-off showing the reporting cut-off date', 'Reconciliation between the site list and the disclosed coverage figure']
We split the workforce data by women and men using the same source records we used for payroll reporting, and we checked the totals before publication.The assurer may probe whether the gender split was based on reliable source data, whether categories were applied consistently, and whether the published totals reconcile to underlying records.['HR or payroll extracts used for the calculation', 'Data dictionary or coding rules for the gender split', 'Reconciliation of gender totals to headcount totals', 'Evidence of review and sign-off before release']
We only included employees whose pay is set against a wage floor, and we kept a working paper showing how we identified that group.The assurer may challenge whether the population was defined correctly, whether exclusions were justified, and whether the method was applied consistently across the group.['Population definition and inclusion/exclusion rules', 'Employee listing or sample used to identify the group', 'Working paper showing the screening process', 'Review notes or approval of the final population']
We calculated the entry pay comparison from the approved wage rates in force at the reporting date and checked the arithmetic before the figure went out.The assurer may test whether the right wage rates were used, whether the comparison basis was consistent, and whether the calculation was accurate.['Approved wage rate schedules and effective dates', 'Calculation sheet showing the comparison basis', 'Evidence of arithmetic checks or independent review', 'Version-controlled final figure used in the report']
For non-employee labour, we mapped the relevant worker groups, tested how their pay was set, and kept evidence for the groups we included and excluded.The assurer may ask whether the non-employee population was complete, whether the pay basis was assessed properly, and whether any exclusions were reasonable.['List of non-employee worker groups in scope', 'Contracts, invoices or labour supplier records', 'Method note explaining how pay basis was assessed', 'Evidence of review of included and excluded groups']
We documented the checks we carried out to see whether those workers were above the wage floor, including the source records and any follow-up queries.The assurer may probe whether the testing was sufficient, whether source records were trustworthy, and whether unresolved exceptions were handled appropriately.['Testing plan or procedure for the wage-floor check', 'Source records used in the review', 'Exception log and follow-up correspondence', 'Sign-off showing completion of the checks']

Evidence pack to prepare

Common reporting gaps

A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner
The request goes to payroll or HR alone, even though the answer needs input from local site teams, reward, and anyone who knows which locations and worker groups matter.
Framework language only
The data call is written in disclosure jargon, so the business cannot tell whether it is about site coverage, worker groups, gender splits, or the wage benchmark being used.
No scope set
People start collecting figures before agreeing which sites count as significant and which worker groups are in or out, so the dataset ends up mixing unlike populations.
Wrong timing basis
One team pulls current pay data while another uses a different cut-off date for the wage benchmark, which makes the comparison inconsistent.
Mixed counting basis
Headcount, full-time equivalent, and pay-rate records are blended in the same file, so the ratio is built from numbers that do not share the same basis.
Source labels lost
The original file names, field names, or local wage references are stripped out during consolidation, leaving no way to trace where each figure came from.
Separate groups merged
Employees and non-employee workers are rolled into one pool, even though the data call treats those groups separately and needs different checks for each.
Evidence trail missing
The working file has numbers but no supporting notes, extracts, or reviewer sign-off, so nobody can show how the figures were checked before reporting.
No local wage choice recorded
Where more than one wage benchmark could apply, the team records the ratio without noting which reference was chosen for each site.
Gender split not captured
The source extract is kept only as a combined total, so the team cannot separate the figures by gender when it comes time to prepare the disclosure.

Where judgement is often needed

Setting the site list for the year
Use a clear, documented rule for which sites count as major operating locations in the reporting period, and explain any additions or removals from purchases, sales, closures or openings.
Choosing the local pay benchmark where more than one exists
If a site can point to more than one wage floor, pick one basis consistently, explain why it was chosen, and note where the local floor is absent or changes by worker group or area.
Defining the entry pay point for each gender view
State the pay grade, job family or starting rate used for the comparison, and keep the same basis across sites unless a local labour rule forces a different approach that you describe.
Deciding who sits inside the comparison group
Explain whether you have included only employees or also other people doing the organisation’s work, and set out the test used to decide when that wider group is large enough to matter.
Handling mixed pay arrangements at the edge of scope
Where some people are paid partly by a wage floor and partly by other pay methods, describe the rule used to include or exclude them and how you treated borderline cases.
Using estimates where payroll data are incomplete
If exact figures are not available for every site or worker group, say which values were estimated, the method used, and whether the same approach was applied across all locations.
Timing the comparison date
Choose a single cut-off date or period-end basis for the wage comparison, apply it consistently, and disclose any site-level timing differences caused by local pay-setting cycles.
Rounding and presentation of the ratio
State the rounding rule used for the percentage comparison and make sure the rounded figure still matches the underlying calculation, especially where the result is close to parity.
Protecting privacy in small groups
Aggregate or suppress site and gender splits where headcounts are too small to share safely, and explain the level at which the figures have been combined.
Examples

Illustrative examples

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

Illustrative (synthetic) example — Food manufacturing

We use our own working definition of major operating sites: locations that account for at least 10% of group headcount or 10% of payroll. In this synthetic example, our UK and Poland sites are the only major locations; both have a local floor for pay, and we show the entry starting rate against that floor by gender, plus the checks we used for contractors and agency staff.

Synthetic illustration only. Shows how to describe major sites, the pay-floor basis used, whether a local floor exists or varies by gender, the entry-rate comparison, and the checks used for non-employee workers.

Illustrative pay-floor comparison at major operating sites (people / %)
UK site: employees paid from local floor120180
UK site: entry starting rate as % of local floor100100
Poland site: employees paid from local floor80120
Poland site: entry starting rate as % of local floor100100
Other workers checked against floor4555
Other workers found above floor4555
Illustrative (synthetic) example — Logistics and warehousing

For this synthetic disclosure, we treat a site as major when it has at least 8% of group staff or 8% of group labour spend. Our main sites are in Germany and Spain; Germany has one local pay floor for all workers, while Spain has no local floor, so we use the statutory national floor there and explain the review steps for agency and subcontracted labour.

Synthetic illustration only. Shows a different way to define major sites, how to state the reference pay floor used where more than one could apply, how to note absence of a local floor, and how to explain checks on non-employee workers.

Illustrative pay-floor comparison at major operating sites (people / %)
Germany site: employees paid from local floor150150
Germany site: entry starting rate as % of local floor100100
Spain site: employees paid from national floor90110
Spain site: entry starting rate as % of local floor100100
Other workers checked against floor6040
Other workers found above floor6040
Company reports

How companies report GRI 202-1

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

Sumitomo Forestry Co., Ltd.
Home Building · Japan · 2025
Open report →
Sumitomo Forestry Co., Ltd.'s Sustainability Report 2025 provides several covered datapoints related to labor practices and diversity, including a reported significant risk for incidents of forced or compulsory labor (p.536) and data on the ratio of female employees to all employees both in the non-consolidated entity and subsidiaries in Japan, with percentages around 24-37% (pp.56, 61). The report also includes information on entry-level wages by gender compared to local minimum wage and proportions of senior management hired, indicating some gender-related wage and employment data (p.530). However, there is no clear headline value or detailed narrative on incidents of discrimination or corrective actions beyond brief mentions, and some contextual information on employee awareness and management actions is partial without specific figures (p.303).
Sims Limited
Solid Waste Management Utilities · Australia · 2025
Open report →
Sims Limited’s 2025 Sustainability Report provides several covered datapoints related to social standards, including a noted significant risk for incidents of child labor (p.67) and gender-related workforce data such as women to men ratios and senior management hiring proportions (pp.64, 67). The report also discusses employee consultation during significant operational changes (p.66) and references detailed workforce diversity and development data (p.62). However, some narrative elements remain unclear or not found, with no quotable evidence for certain aspects and missing methodology or narrative details for disclosure part (d).
KGI Financial Holding Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Open report →
KGI Financial Holding Co., Ltd.’s 2024 ESG Report provides detailed data on workforce composition, including gender distribution with 1,085 employees aged 30-49 and a total of 1,980 employees split 44% male and 56% female (pp.82-83). The report also covers operational scale with 305 total operation locations across major subsidiaries (p.6) and includes information on absenteeism numbers by gender (p.101). However, the report lacks clear narrative or methodological explanation regarding some human rights commitments and local hiring practices, with no quotable evidence found for these aspects in the provided pages.
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Scenarios to work through

A preparer is drafting the pay note for two large sites, one in Manchester and one in Leeds. The local wage floor is set by different rules at each site, and the team has separate starting pay rates for women and men in each place.

QHow should the preparer decide whether to present one combined ratio or separate figures, and what needs to be clear about the locations and gender split?
Reveal model answer →

At one warehouse, most staff are on hourly contracts tied to the legal wage floor, but a small group of supervisors are paid above it. The reporting team is unsure whether the warehouse should be treated as a site where the disclosure is relevant.

QWhat judgement should the preparer make about whether this site belongs in the analysis?
Reveal model answer →

A company uses agency staff and contractors at a distribution centre, and many of them help deliver the organisation’s activities. The HR team has employee payroll data, but it is not yet clear how to evidence whether those non-employees are paid above the local wage floor.

QWhat should the preparer do before concluding that this group can be left out of the wage-floor check?
Reveal model answer →

In one country, there is no single local wage floor at the main site: one region has a statutory minimum, another uses a sector rate, and the site employs both women and men across both areas. The reporting lead is unsure which benchmark to use in the ratio.

QHow should the preparer choose the benchmark and explain the choice?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 202-1
within GRI 202: Market Presence
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I prepare a GRI 202-1 Market Presence disclosure using this page in practice?+
What data do I need to collect for GRI 202-1 Market Presence on this page?+
How should I decide which sites count as key operating sites for GRI 202-1 Market Presence?+
What should I document about the minimum-pay check method for GRI 202-1 Market Presence?+
Who should own the data for GRI 202-1 Market Presence in my organisation?+
What evidence pack do I need to make GRI 202-1 Market Presence assurance-ready?+
What are the six assurance claims I should verify for GRI 202-1 Market Presence?+
What are the common reporting gaps or mistakes for GRI 202-1 Market Presence?+
How can I use the synthetic example disclosure on this GRI 202-1 Market Presence page?+
What can I download to help me draft and assure GRI 202-1 Market Presence?+
How do I turn the GRI 202-1 Market Presence data into a draft disclosure?+
More questions this page can help with
What should I include in the GRI 202-1 Market Presence working papers before I draft the report?How do I make sure my GRI 202-1 Market Presence scope is consistent across sites and data owners?Which GRI 202-1 Market Presence datapoints are most likely to need HR input?How do I evidence the reference wage chosen for GRI 202-1 Market Presence?What should an assurance reviewer look for in a GRI 202-1 Market Presence evidence pack?How do I use the Prep & Assurance workbook for GRI 202-1 Market Presence?What does the printable Library Card help with on GRI 202-1 Market Presence?How do I avoid common mistakes when reporting GRI 202-1 Market Presence?Can I use the synthetic example table as a template for my GRI 202-1 Market Presence draft?What narrative starters does the GRI 202-1 Market Presence page give me?How do I build a GRI content-index line for GRI 202-1 Market Presence?Where can I find real company reports that disclose this topic?