This disclosure asks an organisation to show how pay compares between women and men, using a ratio for basic salary and for total remuneration. In practice, it is about whether the organisation can explain the comparison clearly and consistently, rather than only giving a headline statement about equal pay. The focus is on the reported relationship between women’s and men’s pay, based on the organisation’s own workforce data.
The practical emphasis is on coverage and comparability: the organisation should be clear about which parts of the business are included, and whether the figures reflect the whole organisation or only selected sites, functions, or employee groups. A useful report will make it easy to see the scope of the data, so readers can understand how representative the ratio is and avoid mistaking a partial view for the full picture.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Key datapoints to prepare
How to prepare it
Request pay ratio data from People Analytics
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Use your organisation’s own labels first, then map them to the disclosure fields. For example, use your internal site names, job families, grades, pay elements and reporting periods rather than framework wording, and only translate them into the disclosure terms at the end.
Please provide the GRI 405-2 data for significant locations of operation and employee categories, including the the evidence needed for GRI 405:GRI 405-2.
Why it fails: This uses framework language only and does not tell the owner which internal report, site list, pay basis, source file, or calculation method to use. It also leaves the definition of major operating locations unclear, so the returned data may not match the organisation’s own payroll and reward reporting.
Please send the pay comparison extract for [reporting period] using our internal site list and employee groupings. Include base pay and total pay comparisons for women and men, the source system or file, the calculation method, any exclusions, and the definition used for major operating locations. Please return the table with a short note on assumptions and who can approve it.
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
State which sites were treated as the organisation’s key operating locations, explain how employee groups were defined, and note the basis used to calculate each women-to-men pay comparison.
Explain what the ratios mean in practice by showing whether women’s pay sits below, at, or above men’s pay within each employee group and across the organisation’s main operating sites.
If the ratios moved materially from the prior period, link the change to shifts in employee mix, site coverage, or pay-setting decisions, and note any one-off effects that affected the result.
Preparation tools & forms
Professional preparation tools for GRI 405-2 — 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.
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Mistakes to avoid when collecting the data
Where judgement is often needed
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
We have set out a synthetic illustration of pay comparison across our main operating sites, using our own working definition of major locations as those with 250 or more employees or where a site is operationally critical. The figures below compare women and men in each employee group at those sites, showing both base pay and total pay on a like-for-like basis.
Illustrative only: this example shows how a reporter might present the pay comparison for major sites and employee groups, alongside the site-screening rule used.
This synthetic illustration uses a site threshold of 100 or more workers, plus any depot that handles national fulfilment, to define the locations included. It compares women and men across our employee groups at those locations, for both base salary and overall pay.
Illustrative only: this example shows a different plausible way to define major locations and present the same pay comparison by employee group.
How companies report GRI 405-2
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Scenarios to work through
A group reports pay data for three large sites: one in Manchester, one in Leeds and one in Dublin. The HR team has separate figures for shop-floor staff, supervisors and managers, but the draft note only lists the overall company average.
A preparer has calculated that women’s base pay is 92% of men’s in one employee group, but the remuneration figure is 88% because bonuses and allowances differ. The draft currently shows only the 92% figure because it looks simpler.
The payroll team has used the phrase 'major operating sites' in the draft, but the internal methodology actually defines the relevant places as the three sites where most staff are based and where pay data is complete. The sustainability team is unsure whether to keep the internal phrase or explain it.
A draft table lists the ratios for women to men as 101% for senior managers and 97% for all other staff, but it does not say which employee groups those numbers relate to or whether the same site set was used for both measures. The team assumes the figures speak for themselves.
Related framework references
How this disclosure maps across the major reporting frameworks.
Questions this page answers
The page says to prepare five datapoints: key operating sites, worker group split, base pay gender ratio, total pay gender ratio, and the basis used to define a site. It also has a step-by-step preparation section you can use to organise the work.
Use the page’s plain-language explainer and the site definition basis datapoint to set a consistent scope before you calculate the ratios. The worker group split is also a core input, so make sure the groups you use are clear and repeatable.
The page treats site definition basis as one of the datapoints to prepare, so it is part of the methodology you need to document. It helps show how you decided which locations count as key operating sites for the disclosure.
The page is aimed at sustainability and ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can explain the data and evidence. Use the step-by-step preparation section and evidence pack to make responsibilities clear.
The page includes an evidence pack with five items for assurance readiness, alongside five assurance claims to verify. Use those together so the pack supports the claim, the risk, and the evidence for each point.
The page lists common reporting gaps and mistakes, so it is useful as a pre-submission check. In practice, use it to spot missing scope detail, weak methodology, or incomplete supporting evidence before you draft.
The page has a draft-output section with visualisation ideas, narrative starters, and a GRI content-index line. That gives you a practical way to move from the prepared datapoints into a first draft.
Yes — the Download Centre includes a Prep & Assurance workbook in .xlsx format, which is designed to support both preparation and assurance readiness. The page also offers a printable Library Card in PDF form if you want a lighter reference copy.
The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the disclosure might look in practice. Treat it as a worked example only and make sure any figures you prepare are internally consistent.
The table links to real published reports where the topic is disclosed, so it is useful for seeing how others present the information. Use it for inspiration on structure and presentation, not as a substitute for your own data and methodology.
The page says the closest ESRS correspondence is ESRS S1 (Own Workforce), so the same underlying data may be reusable. It does not say the requirements are identical, so you still need to check the other framework’s own disclosure needs.
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