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GRI 405: Diversity and Equal Opportunity · 2016
Disclosure GRI 405-1

Diversity of governance bodies and employees

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 diverse its governance body and employee population are, using the categories it has chosen to report. In practice, it is about showing the make-up of these groups rather than making a general statement about commitment to diversity. The organisation should present the information clearly enough for readers to understand who is represented and where any gaps or imbalances may be.

The practical focus is on coverage and consistency: the reporting should reflect the organisation’s relevant operations and workforce, not just a few well-known sites or a single business unit. For governance bodies, the emphasis is on the main decision-making group; for employees, it is on the wider workforce picture. The key question is whether the reported data gives a fair view of diversity across the organisation as a whole.

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
Gender split The wording used to describe how people are grouped by gender for this disclosure, using the organisation’s chosen categories. HR or people data extract; diversity reporting definitions; any employee self-identification fields and category mapping. People / HR
Age bands The age group labels used to present people in this disclosure, with the organisation’s own banding approach. HRIS age field; reporting dictionary showing band cut-offs; payroll or personnel records used to derive age. People / HR
Other diversity markers Any additional diversity characteristics the organisation chooses to report here, beyond gender and age, stated in plain business terms. Diversity and inclusion reporting pack; HR data definitions; employee survey outputs if used to populate the field. People / HR
Governing group The name of the organisation’s top decision-making group used for this disclosure, including the body being counted. Governance structure chart; board or committee register; annual report governance section. Company Secretariat / Governance
Governance share The share of people in the organisation’s governing group, expressed as a percentage and based on the agreed population for that body. Board or committee membership list; headcount basis used for the calculation; calculation workbook showing numerator and denominator. Company Secretariat / Governance
Worker groups The employee group names used by the organisation for this disclosure, such as the internal categories used in HR reporting. HRIS employee classification table; payroll grouping rules; organisation chart or workforce reporting definitions. People / HR
Workforce mix The percentage of employees in each employee group, using the organisation’s agreed category definitions and the same workforce population throughout. HRIS headcount extract; payroll reconciliation; calculation file showing each category total and overall employee total. People / HR
+ Show GRI 405-1 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first. Decide which governance groups and which employee groupings are in scope, and keep that boundary consistent across the whole disclosure.
2Define the categories you will use before you start counting. Use one clear label for gender, one for age bands, one for any other diversity markers you are reporting, plus the employee categories and the governance group structure you will apply.
3Gather source records that can support each figure or statement. For the governance side, collect the headcount basis and the total number of people covered; for the workforce side, collect the headcount basis for each employee category.
4Calculate the shares and prepare the narrative. Show the proportion of people in each governance group and the proportion of employees in each employee category, and explain any diversity indicators you are using beyond gender and age.
5Record any exclusions, assumptions, or changes in method. If a group is left out, or if the way you classify people has changed since the last report, note that clearly so the reader can understand the figures.
6Check the draft against the source material before sign-off. Confirm that every required item is covered, the percentages are internally consistent, and the wording matches the underlying records without adding anything unsupported.
Request the data

Request the diversity split data from HR / People Analytics

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

How are our board-level groups and employee groups split by gender, age band and any other diversity markers we track, and what share sits in each internal category?

Use your organisation’s own people-data labels first, then map them to the reporting categories. For example, ask for the board, committee members, employee groups and any diversity fields already held in your HR or governance systems, rather than using framework wording in the request.

Weak request

Please send the diversity data for governance bodies and employees in line with the disclosure.

Why it fails: It uses framework language only, so the owner may not know which internal populations, systems or labels to pull from. It also leaves out the period, boundary, counting basis and the specific fields needed to build the extract.

Better request

Please send the extract from your people or board systems for [period], using our internal group names. Include the board and any committees we report on, employee categories, gender, age band and any other diversity fields already held, plus the basis used, the source system, and any exclusions.

Formal email template
Subject: Request for people and board diversity data for [reporting period]

Hi [name/team],

Could you please share a data extract for [reporting period] covering the groups we include in our sustainability reporting boundary?

Please use our internal labels for the relevant populations first, then we can map them for reporting. We need:
- the board and any committees or similar groups we include
- employee groups by our internal category names
- the diversity fields already held in your system for those groups, including gender, age band and any other diversity markers we track
- the basis used for the counts or percentages
- the source system and extract date

Please also include a short note on any exclusions, such as contractors or other people not included in the extract.

If helpful, you can return this in a table using the fields below. Please check the source data before sign-off and let me know if anything is unclear.

Thanks,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name] — could you send the people/board diversity extract for [period]? Please use our internal group names first, then we’ll map them for reporting. We need the board/committee groups, employee categories, gender, age band and any other diversity fields you hold, plus the basis, source system and any exclusions. Thanks.
Industry examples
Financial services

Context. The organisation tracks board membership in the company secretariat tool and employee data in the HR system, with age bands and gender recorded for all staff.

Adapted request. Please provide the board register extract and the employee diversity extract for [period]. Use our internal labels for directors, committee members and employee groups, and include gender, age band and any other diversity fields already held in the HR system, plus the counting basis, source and exclusions.

Example response. Board register with each director and committee member, their internal group label, gender and age band; HR extract with each employee category, headcount, gender split, age-band split and notes on any records excluded from the report boundary.

Manufacturing

Context. The organisation has a factory workforce, office staff and a small executive board. Diversity data is held in payroll and HR records, with some fields missing for legacy employees.

Adapted request. Please send the workforce and board diversity extract for [period], using our site and office group names. Include the board, leadership team and employee categories, with gender, age band and any other diversity fields we already hold, plus a note on missing records and the basis used for the percentages.

Example response. A table by internal group showing headcount and percentage split by gender and age band, plus a separate note listing legacy records with missing diversity fields and confirming the extract came from payroll and HRIS.

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 which groups were counted, how each diversity category was defined, and whether the figures cover the full population or only those with recorded data.

Context note

Explain what the percentages say about the make-up of the board and workforce, and note whether the picture suggests broad representation or concentration in a few groups.

Fluctuation statement

If the mix has changed since the prior period, point to the main drivers such as recruitment, departures, promotions or changes in how people chose to self-identify.

Content index entry
GRI 405-1 Diversity of governance bodies and employees — [location / page] / [notes]
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Preparation tools & forms

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We prepared the coverage figure from our own records for the reporting period and checked that the population included in the calculation matched the basis we said we used.An assurer may test whether the population was defined consistently, whether any parts of the business were left out without explanation, and whether the figure could be reproduced from source records.Population definition note; reporting boundary memo; source extracts from HR or governance records; calculation workbook; reconciliation to the final figure; sign-off showing the basis used was approved before publication.
For the split by sex, we used the underlying people data held in our systems and reviewed it for completeness and obvious coding errors before the report went out.An assurer may probe whether sex data were current, whether missing or ambiguous records were handled consistently, and whether the published split agrees with the source population.HR master data extract; data dictionary for sex fields; exception log for missing or unclear records; validation checks; final calculation file; review and approval trail.
For the age profile, we calculated the figure from date-of-birth information held at the cut-off date and checked that the age bands were applied the same way across the dataset.An assurer may test whether the cut-off date was applied consistently, whether age was derived correctly, and whether the banding method was changed or applied unevenly.Source employee or member records; cut-off date instruction; age-band methodology note; calculation workbook; sample re-performance of age derivation; reviewer sign-off.
Where we included other diversity markers, we relied on the fields we had available and documented any gaps, proxies, or exclusions so the reader can see how the figure was built.An assurer may ask whether the additional markers were defined clearly, whether proxies were used without disclosure, and whether missing data could distort the result.Method note for each additional marker; source-system fields used; gap analysis; explanation of any proxy or exclusion; evidence of management review of the chosen approach.
For the board-level figure, we used the list of current directors and checked the membership against corporate records before finalising the disclosure.An assurer may examine whether the board population was complete, whether appointments or resignations were captured at the right date, and whether committee members were included or excluded consistently with the stated basis.Board and committee register; company secretariat records; effective-date listing; reconciliation between governance records and the reported population; approval from the company secretary or equivalent.
When we calculated the share for the board, we matched the relevant people count to the agreed total and confirmed the arithmetic before publication.An assurer may test the denominator, the numerator, rounding, and whether the percentage can be traced back to the underlying count without mismatch.Calculation sheet showing numerator and denominator; rounding policy; cross-check to the board register; independent arithmetic review; final proof copy.

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 data owner
Chasing the board secretary for staff headcount, or HR for director data, leaves the figures split across teams that do not hold the same records.
Framework language used in the request
Asking for the data in disclosure terms instead of the organisation’s own job, committee, and workforce labels makes the source team unsure what to pull.
Scope not pinned down
Collecting numbers without stating which parts of the business, which entities, or which people are in scope leads to a set that cannot be reconciled later.
Wrong period basis
Mixing a year-end snapshot with an average over the period produces figures that are not built on the same timing basis.
Counting rules mixed
Combining full-time equivalents, individual people, and percentage shares in one file makes the totals impossible to check against each other.
Source labels stripped out
Copying values into a clean spreadsheet without the original team names, category labels, or source codes breaks the link back to the evidence.
Populations merged too early
Putting directors, committee members, and employees into one pool before separating them by the right group hides which figures belong where.
Evidence metadata missing
Saving the numbers without the date pulled, file version, owner, or system reference leaves no way to show where each figure came from.
No review trail
If the draft is passed around without a named checker and sign-off record, no one can show who confirmed the final data set.

Where judgement is often needed

Choosing the reporting perimeter after a buy-in or sale
If a business has been bought, sold, or restructured, set out which parts of the group are counted for the year-end snapshot and explain any cut-off date used so readers can see why the headcount mix changed.
Using local labels versus one group-wide people map
Where countries use different job grades or staff groupings, map them to a single internal set of people categories, explain the mapping, and note any places where a local label does not fit neatly.
Deciding who counts as part of the board set
Be explicit about whether you include only directors or also committee members and similar appointees, and explain any exclusions for people who attend but do not hold a formal seat.
Handling workers on the boundary of employee status
State the rule used for people such as fixed-term staff, agency workers, interns, or secondees, and explain whether they sit inside the employee population or are left out.
Selecting the point-in-time basis for percentages
Use one clear date or period-end basis for the percentages, explain that choice, and keep it consistent across the board and workforce figures unless a change is clearly described.
Mixing system data with estimates
If some diversity attributes are not held in HR or board records, say where estimates or self-declared information were used, describe the method briefly, and flag any material gaps.
Rounding small populations without distorting the picture
Round percentages in a way that does not mislead when the underlying group is small, and explain any cases where rounding means the displayed figures do not add neatly to 100%.
Protecting privacy in small or sensitive groups
When a category is so small that individuals could be identified, combine or suppress the split as needed, explain the aggregation rule, and make clear that this was done to avoid exposing personal data.
Defining the extra diversity markers beyond gender and age
For any other diversity markers you choose to report, state the internal definition used for each one and explain why that measure is the one the organisation relies on across its people data.
Examples

Illustrative examples

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

Illustrative (synthetic) example — Retail banking

Synthetic example only: we show the make-up of our board and senior committees, plus our workforce split by job level. The figures below are illustrative and internally consistent.

Use this disclosure to show how the organisation’s leadership group and workforce are distributed across the requested diversity dimensions, with percentages calculated from the relevant headcount base.

Illustrative breakdown of board, committees and workforce by diversity dimension (people)
Board and board committees851
Senior leadership group14102
Management62486
Professional staff21016525
Operational staff18012020
Illustrative (synthetic) example — Food manufacturing

Synthetic example only: we present the composition of our governing group and committees, together with our employee mix by grade. The numbers are illustrative and each percentage is rounded from the headcount shown.

Use this disclosure to present the diversity profile of the top governance group and its committees, and to break down employees by category with a percentage for each category based on the total workforce.

Illustrative breakdown of governance and workforce composition by diversity dimension (people)
Top governance group and committees671
Executives9110
Middle management34264
Skilled production968410
Support functions58428
Company reports

How companies report GRI 405-1

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

MOEVE, S.A.
Oil and Gas · Spain · 2025
Open report →
Moeve, S.A.'s 2025 Consolidated Management Report provides detailed data on gender distribution across various employee categories and age groups, with specific percentages and headcounts reported on pages 117 and 121. The report includes diversity metrics for governance bodies and employees, highlighting gender representation in management committees and overall workforce composition (p.117, p.151). However, there is no clear narrative or qualitative discussion on diversity and inclusion policies or outcomes beyond these figures, and some sections lack explicit commentary on the implications of the data presented.
Temenos AG
Software and Services · Switzerland · 2025
Open report →
Temenos AG's Sustainability Report 2025 provides detailed data on gender diversity, reporting a consistent 35% female representation in the total headcount for 2023 through 2025, with targets to exceed 35% by 2026 and reach 40% by 2030 (p.56). The report also includes age group distributions and governance framework details related to sustainability governance and diversity dashboards (pp.39, 55, 92). However, there is no clear information on turnover rates or other diversity metrics beyond gender and ethnicity representation in the US, and some expected narrative items are not found in the report.
Companhia Paranaense de Energia - COPEL
Electric Utilities / IPP / Energy Traders · Brazil · 2024
Open report →
Companhia Paranaense de Energia - COPEL's 2024 Integrated Report provides detailed gender distribution data, showing men constitute a majority across various categories, such as 86.0% to 94.1% in one breakdown on page 260 and 78.1% overall on page 261. The report also references governance structures related to diversity, including a Diversity Committee and personnel admission processes on page 259, and governance body roles on page 305. However, there is no clear information on other diversity dimensions beyond gender and age, and some narrative elements lack specific data or are not found in the report.
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Scenarios to work through

A listed group has a board of 10 people and two board committees. The draft note gives the board split by gender and age, but it leaves out the extra diversity factors the company uses in its own reporting framework.

QShould the note stop at gender and age, or also include the other diversity factors the organisation has chosen to report for the board and its committees?
Reveal model answer →

A company has three employee bands in its HR system: senior leaders, managers and all other staff. The draft table shows headcount percentages for senior leaders and managers, but the ‘all other staff’ band is missing because the team thought it was too broad.

QCan the employee section be left incomplete if one category is hard to summarise neatly?
Reveal model answer →

A preparer has a draft for the board showing 4 women and 6 men out of 10 directors, and a separate line saying the average age is 52. The team is unsure whether the percentages should be shown for the board as a whole or only for the women and men sub-groups.

QHow should the percentage information be framed so it matches the disclosure intent?
Reveal model answer →

An organisation has a small executive committee of 5 people and a wider workforce of 200 employees. The draft report uses one combined table for both groups, but the labels do not make it clear which percentages belong to the committee and which belong to employee bands.

QIs it acceptable to combine the two sets of figures in one table if the labels are not very explicit?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 405-1
within GRI 405: Diversity and Equal Opportunity
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I prepare a GRI 405-1 Diversity and Equal Opportunity disclosure using this page without missing the key datapoints?+
What data do I need to collect for GRI 405-1 Diversity and Equal Opportunity before I start drafting?+
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Can I use the synthetic example on the GRI 405-1 Diversity and Equal Opportunity page as a model for my own disclosure?+
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