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GRI 3: Material Topics
Disclosure GRI 3-3

Management of material topics

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 manages each material topic in practice. In plain terms, it is about showing what policies, processes, responsibilities and actions are in place to address the topic, rather than simply saying the topic is important. The report should make clear how the organisation turns its materiality assessment into day-to-day management.

The practical focus is on whether the approach is embedded across the organisation and relevant parts of the value chain, not just described for a few flagship sites or isolated initiatives. A useful explanation will show the scope of coverage, who is accountable, and how the organisation monitors whether its management approach is working over time.

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
Impact overview A plain-language summary of the organisation’s actual and possible effects, both harmful and beneficial, across economic, environmental and social areas, including any effect on people’s rights. Materiality assessment, impact mapping, issue papers, risk and opportunity registers, human rights due diligence outputs, stakeholder input. Sustainability / ESG reporting
Source of harm State whether the organisation is linked to the harmful effects through its own operations, or through relationships with suppliers, partners or other counterparties. Value-chain mapping, supplier/partner due diligence, incident logs, legal or compliance reviews, issue ownership papers. Sustainability / ESG reporting
Linked activities Name the specific operations, services, products, suppliers, customers or other relationships that connect the organisation to the harmful effects. Process maps, contract lists, supplier/customer registers, operating model documentation, due diligence files. Sustainability / ESG reporting
Policy commitments Summarise the organisation’s stated rules, principles or promises for handling the material issue. Approved policies, public commitments, code of conduct, board papers, policy register. Policy / Governance
Management actions Describe the steps the organisation has taken to deal with the issue and the related effects, covering both current and expected impacts where relevant. Action plans, project trackers, remediation logs, control updates, management meeting minutes. Issue owner / Operational management
Prevention measures List the steps taken to stop likely harmful effects from happening, or to reduce how severe they could be. Risk treatment plans, control design documents, training records, supplier action plans, preventive audit findings. Risk / Operational management
Remediation actions Set out the steps taken to deal with harm that has already happened, including repair, compensation, cooperation or other remedy arrangements. Incident investigations, grievance records, remediation agreements, compensation approvals, legal or claims files. Legal / Compliance / Operational management
Positive impact actions Describe the actions taken to strengthen or expand beneficial effects that are already happening or could happen. Programme plans, investment cases, partnership agreements, outcome reports, benefit tracking dashboards. Sustainability / Strategy / Business unit lead
Effectiveness tracking Explain how the organisation checks whether its actions are working, including the monitoring approach, measures used and how results are reviewed. Monitoring framework, KPI packs, assurance reports, review meeting minutes, dashboard definitions. Performance management / ESG reporting
Monitoring process Describe the practical process used to follow up on action performance, including who reviews it, how often, and from which systems or reports. Process maps, governance calendars, dashboard extracts, review packs, control testing records. Performance management / Operations
Measures and targets List the goals, targets and indicators used to judge progress, with clear definitions and measurement basis. Target-setting documents, KPI dictionaries, scorecards, board packs, metric calculation notes. Performance management / ESG reporting
Progress and results State how far the organisation has moved toward its goals and targets, and whether the actions have worked as intended. Trend analysis, KPI results, target trackers, evaluation reports, assurance statements. Performance management / ESG reporting
Learning and updates Capture the main lessons from implementation and show how those lessons have been built into operating rules and procedures. Post-implementation reviews, lessons-learned logs, policy updates, procedure revisions, change approvals. Operational management / Policy
Stakeholder input Explain how feedback from stakeholders shaped the actions chosen and how it influenced the judgement on whether those actions were effective. Engagement logs, consultation summaries, grievance themes, meeting notes, response trackers. Stakeholder engagement / ESG reporting
+ Show GRI 3-3 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which parts of the business, value chain links, and topic areas you are covering, so the disclosure is tied to the material issue you have identified.
2List what you will count as an impact and what you will not: capture both harmful and beneficial effects, including effects on people’s rights, and note whether any harm comes from your own operations or from commercial ties.
3Gather the source material behind each statement: pull together internal records, issue logs, policy documents, action plans, monitoring outputs, targets, indicators, and any stakeholder input that shaped the response.
4Draft the content in the order the disclosure needs it: explain the issue, the links to your activities or relationships, the relevant policies or commitments, the actions taken, and how you are checking whether those actions work.
5Separate the action types clearly: show what you are doing to stop or reduce likely harm, what you are doing to deal with harm that has already happened, and what you are doing to manage beneficial effects.
6Record any exclusions, scope changes, or judgement calls, then compare the final wording against the official source to confirm you have covered every required point without adding or omitting anything.
Request the data

Request the material-topic management evidence from the topic owner

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

How is this topic being managed in practice, what actions are in place, how are they tracked, and what evidence shows they are working?

Use your organisation’s own names for the topic, teams, controls, plans and performance measures first, then map them to the reporting wording. Keep the request in business language that the owner already uses, and check the source disclosure before sign-off.

Weak request

Please provide the GRI 3-3 information for the material topic, including impacts, actions, tracking, and stakeholder engagement.

Why it fails: It uses framework language only, so the owner has to translate the ask before they can answer. It also does not say what internal records, measures, or source files are needed, so the response is likely to be incomplete or hard to verify.

Better request

Please send the evidence pack for [internal topic name] covering [period]: the main impacts we have seen or may see, whether they come from our own work or our business links, the controls or commitments in place, the actions taken, how progress is tracked, any lessons learned, and any stakeholder input that shaped the response. Include the source system, owner, and supporting files.

Formal email template
Subject: Request for evidence on [internal topic name]\n\nHi [name/team],\n\nWe are preparing the sustainability report section for [reporting period] and need your help with the evidence for [internal topic name].\n\nPlease send the information below in your own working terms, and we will map it to the reporting wording afterwards:\n- a short description of the main actual and possible impacts, including any effects on people, communities, the environment, and any human-rights-related issues\n- whether the issue arises from our own activities, our business links, or both, plus a brief description of those activities or links\n- the policies, commitments, standards, or procedures that guide how the issue is handled\n- the actions taken to prevent, reduce, fix, or improve the impacts\n- how those actions are monitored, including the measures, targets, and progress updates used\n- any lessons learned and changes made to policies or procedures\n- any stakeholder input that shaped the actions or the view on whether they are working\n\nPlease include the source file/system, the period covered, the owner, and any links to supporting documents. If there are gaps, please flag them clearly.\n\nThanks,\n[preparer name]
Short Teams / Slack version
Hi [name] — could you share the evidence pack for [internal topic name] for [period]? We need: main impacts, whether they come from our own activity or business links, the policies/commitments in place, actions taken, how you track progress, any lessons learned, and any stakeholder input. Please include the source file/system and owner. We’ll map it to the reporting wording later.
Industry examples
Manufacturing

Context. A plant team manages workplace safety and contractor control across several sites.

Adapted request. Please send the evidence pack for site safety for [period]: the main actual and possible impacts on workers and contractors, whether these arise from our own site activities or from contractor relationships, the site rules and commitments in place, the actions taken to prevent incidents or fix issues, how you track close-out and performance, any lessons learned, and any worker or contractor feedback that changed the approach. Include the incident log, audit tracker, and site procedure references.

Example response. Attached: site safety dashboard, incident log extract, contractor audit tracker, updated site procedure v4, and meeting notes from worker reps. The pack covers all UK sites for FY2025 and shows actions, closure rates, and procedure updates.

Retail / Consumer Goods

Context. A commercial team manages supplier labour standards and responsible sourcing.

Adapted request. Please send the evidence pack for supplier labour standards for [period]: the main actual and possible impacts linked to our sourcing activity and supplier relationships, the supplier code and commitments in place, the actions taken to prevent, reduce, or remedy issues, how supplier performance is tracked, any lessons learned, and any input from suppliers, auditors, or worker groups that influenced the response. Include the supplier scorecard, audit reports, and remediation tracker.

Example response. Attached: supplier code, audit summary, remediation tracker, quarterly scorecard, and notes from supplier engagement calls. The pack covers Tier 1 suppliers in scope for FY2025 and shows audit findings, corrective actions, and follow-up status.

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

Define the scope of the assessment, the basis used to identify and classify impacts, the sources of evidence used, and how the organisation distinguished between effects linked to its own operations and those connected through business relationships.

Context note

Explain what the figures mean in practice by linking the identified impacts, the response measures, and the tracking results to the organisation’s material topic and its wider economic, environmental, social, and human-rights effects.

Fluctuation statement

If results changed during the period, explain whether that was driven by new actions, revised tracking methods, changes in business relationships, stakeholder feedback, or a shift in the underlying impact profile.

Content index entry
GRI 3-3 Management of material topics — [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
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

Wrong owner
The data request goes to a team that only sees part of the issue, so the answer misses the people who actually run the controls, actions, or tracking.
Framework language only
The request is written in reporting jargon instead of the organisation’s day-to-day terms, so the right colleagues do not recognise what evidence is being asked for.
No scope set
The team collects information without fixing which sites, entities, activities, or relationships are in scope, so the final pack mixes unlike cases.
Wrong time basis
Evidence is pulled for the wrong period or cut-off date, so the figures and examples do not match the reporting window being used.
Mixed counting basis
Headcounts, cases, or incidents are combined even though they were recorded on different bases, which makes the totals inconsistent and unusable.
Source labels lost
Original file names, system tags, or case references are stripped out during collection, so nobody can trace each point back to its source.
Separate groups merged
Data for different populations or channels is rolled together even though they should stay apart, which hides important differences in the underlying issue.
No evidence trail
The pack is assembled without dates, owners, or approval notes, so there is no clear record of where the information came from or who checked it.

Where judgement is often needed

Set the reporting perimeter after a deal closes or a site leaves the group
State the cut-off you used for bringing newly acquired operations into scope, or removing sold ones, and explain any one-off treatment for the period so readers can see why the topic picture changed.
Choose one business definition where local rules differ
If the same topic is defined differently across countries or business units, pick the working definition you used for the report, say where it differs from local practice, and explain the basis for that choice.
Decide how to treat people or activities that sit just outside the main scope
Explain whether you included nearby workers, contractors, customers, communities or other affected groups that are not fully inside the core operating boundary, and why that treatment best reflects the topic’s real reach.
Fix the time basis for actions and results
Be clear whether you are describing the position at period end, the full year, or another cut-off, and explain any lag between taking an action and seeing its effect.
Separate measured figures from estimates
Where direct counts are not available, disclose which figures are based on estimates or proxies, how they were derived, and whether the same method was used across the period and locations.
Round numbers without hiding the underlying picture
Use a consistent rounding approach, note it where it could affect interpretation, and make sure totals still reconcile after rounding so the scale of action and impact remains clear.
Aggregate sensitive people data to protect privacy
If individual-level information cannot be shown, present it in grouped form, explain the aggregation rule, and keep enough detail to show how the actions and outcomes were tracked without exposing personal data.
Explain how you handled mixed evidence across the group
When some parts of the business have strong records and others have partial or weaker evidence, say how you combined them, what assumptions filled the gaps, and how that affects confidence in the reported result.
Examples

Illustrative examples

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

Illustrative (synthetic) example — food processing

*Synthetic illustration only.* We focus on water use and labour conditions in our own sites and in a few key suppliers, where our operations can create both harm and benefit for local communities, workers and the natural environment, including rights-related risks. We are linked to the main harms through our own production activities and, in some cases, through business partners; our policy sets minimum labour, water and discharge standards, and we use supplier clauses, site controls and worker grievance channels to prevent or reduce likely harm, while also correcting confirmed issues through remediation, supplier improvement plans and, where needed, cooperation with affected parties. - To support beneficial outcomes, we run local hiring, skills and water-efficiency programmes, and we track progress through monthly site audits, supplier scorecards and complaint logs against targets for reduced water intensity, fewer substantiated labour cases and faster closure of corrective actions. - In the year shown, 18 of 20 sites met the water target, 14 of 16 priority suppliers completed improvement plans, and 9 of 10 worker complaints were resolved within 30 days; stakeholder input from workers, community groups and buyers led us to tighten contractor oversight and add a formal review step to our operating procedures after we learned that some issues were recurring at shift-change handovers.

This synthetic example shows how a reporter can cover both adverse and beneficial effects, explain where the link to the issue comes from, and connect controls, remediation, monitoring and stakeholder input in one narrative.

Illustrative (synthetic) example — renewable energy services

*Synthetic illustration only.* Our project work can affect land access, biodiversity, safety and local livelihoods, while also creating cleaner power, jobs and training; these effects can be direct from our own activities or indirect through contractors and land partners, and some carry human-rights implications for nearby residents and workers. Our commitments require fair land engagement, safe working practices and biodiversity safeguards, and we manage the topic through early consultation, contractor rules, incident response, community liaison and restoration plans so that likely harm is avoided or reduced, confirmed harm is repaired or supported through cooperation, and positive outcomes are expanded through local procurement and training. - We assess how well these steps work using permit-condition checks, incident reviews, community feedback and quarterly management reviews, with indicators for land-access complaints, safety events, habitat restoration and local spend; our 2025 goals were to cut land-access complaints to no more than 4, keep recordable safety events below 2, restore 100 hectares and raise local spend to 35%. - Results for the year were 3 land-access complaints, 1 recordable safety event, 100 hectares restored and 34% local spend; after hearing from residents and local authorities, we changed our consultation timetable, added clearer contractor briefing notes and embedded a lessons-learned register into our operating procedures so the same issues are less likely to recur.

This synthetic example illustrates a second plausible reporter with different impacts and controls, while still showing the source of impacts, the response, monitoring, outcomes and how stakeholder views changed the approach.

Company reports

How companies report GRI 3-3

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

China Steel Corporation
Mining — Iron, Aluminum, Other Metals · Taiwan · 2024
Open report →
China Steel Corporation’s Sustainability Report 2024 provides covered evidence on sustainable value creation of steel products with a positive impact on the environment and economy (p.18), as well as details on activities, value chain, and employees (p.79). The report also includes information on business strategy and finances over short, medium, and long terms (p.84). However, several narrative items, including (c), (d), and (e) and their sub-items, are not found or unclear in the report, indicating gaps in coverage for those specific disclosure elements.
GeelongPort
Water Transportation — Ports and Services · Australia · 2025
Open report →
GeelongPort’s Sustainability Report 2025 includes coverage of mechanisms for seeking advice and employee engagement, with references on pages 44, 48, 53, and 84 indicating some reporting on negative impacts and how the company listens to stakeholders (p.84). The report also addresses social considerations in supplier selection, highlighting a commitment to social, environmental, or community-oriented purposes (p.63). However, several narrative items, including those related to specific disclosures (c), (d), (e), and (f), are not found or are unclear in the report, indicating gaps in coverage for these aspects.
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 provides data on human rights violations, reporting zero cases and noting that 78% of the Board of Directors are independent with an average seniority of 2.1 years (p.14). The report also addresses the impacts of its activities on biodiversity, referring readers to detailed management actions in an annex covering pages 90 to 94 (p.147). However, several narrative items related to specific disclosures, including detailed methodologies and certain action plans, are not found or remain unclear in the report.
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Scenarios to work through

A manufacturing group has identified worker safety and local air emissions as key issues. Its draft note covers accident trends and pollution controls, but it says nothing about possible future harm, any upside from cleaner processes, or effects on nearby communities.

QWhat should the preparer add so the note gives a full picture of the issue being managed?
Reveal model answer →

A retailer sources most of its own-brand products through third-party suppliers. The draft says the company is “linked to labour concerns in the supply chain” but does not explain whether the issue comes from its own operations, from supplier ties, or both.

QHow should the preparer explain the company’s connection to the negative impact?
Reveal model answer →

A services firm has a policy on fair treatment of contractors and a programme to reduce late payments to small suppliers. It also runs a grievance channel, but the draft only lists the policy and the channel without saying what is being done to stop harm, fix harm already caused, or build on positive effects.

QWhat actions should the preparer describe to make the management response complete?
Reveal model answer →

A food producer says it has introduced supplier audits and worker training, but the draft gives no detail on how it checks whether those steps work. It also mentions a target to cut grievances by 20% but does not say how progress is measured or what has been learned from worker feedback.

QWhat should the preparer include about checking whether the actions are working?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 3-3
within GRI 3: Material Topics
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I prepare a GRI 3-3 Material Topics disclosure using this page’s step-by-step guidance?+
What information do I need to collect for GRI 3-3 Material Topics before I start drafting?+
How should I decide the scope and methodology for a GRI 3-3 Material Topics disclosure?+
Who should own the inputs for GRI 3-3 Material Topics in my organisation?+
What evidence pack do I need to make a GRI 3-3 Material Topics disclosure assurance-ready?+
What are the common mistakes to avoid when drafting GRI 3-3 Material Topics?+
How do I use the Prep & Assurance workbook for GRI 3-3 Material Topics?+
What can I do with the printable Library Card for GRI 3-3 Material Topics?+
Can I use the synthetic example disclosure on this page as a template for my own GRI 3-3 Material Topics draft?+
How do I turn my GRI 3-3 Material Topics data into a draft narrative and content-index line?+
More questions this page can help with
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