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ESRS G1: Business Conduct·Disclosure Requirement G1-4
Corruption & Bribery Metrics
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official European Commission source.
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Prepared from official source material and published report evidence. No named approver is recorded yet, so this page carries no byline.
Use it alongside the official European Commission source while that review is in progress.
Standard
ESRS G1: Business Conduct
Disclosure Requirement G1-4 · 2026-5010-final
Last reviewed
—
LRA educational guidance · Not issued or endorsed by European Commission
To prepare this disclosure
Disclosure focus
This disclosure asks an organisation to report the numbers that show how it manages corruption and bribery risks in practice. The focus is on measurable information, such as how many relevant incidents, allegations, investigations, training completions, or other tracked events there are, so readers can see whether the organisation’s anti-corruption controls are active and being used, not just described in policy documents.
In practical terms, the reporting should cover the organisation’s full relevant footprint, not only a few well-controlled or flagship locations, unless the scope is clearly explained. The key question is whether the figures reflect the parts of the business where corruption and bribery risk actually exists, including operations, subsidiaries, and other relevant activities, so users can judge the breadth and consistency of the organisation’s approach.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Conviction count | Record the total number of convictions that fall within the reporting scope for the period. | Court records, legal case logs, compliance register, or a legal affairs summary that reconciles to the final count. | Legal / Compliance |
| Sanction count | Capture the total number of sanctions that apply to the reporting scope for the period. | Regulatory notices, enforcement tracker, compliance register, or a legal affairs summary that ties to the reported total. | Legal / Compliance |
| Total fines amount | Capture the full euro amount of fines that belong in scope for the period, using the same basis across all included items. | Penalty notices, finance/legal schedule, or an enforcement summary that reconciles to the euro total reported. | Finance / Legal |
＋ Show G1-4 sub-elements (LRA working checklist)
Count how many convictions were recorded.
Count how many sanctions were imposed.
Add up the total fines in euros.
How to prepare it
Set the reporting boundary first: decide which parts of the business, subsidiaries, and relevant reporting period are in scope for this disclosure, so the figures and narrative are built from the right population.
Agree what each metric will count before you start collecting data: define how you will treat convictions, sanctions, and monetary penalties, and make sure the same approach is used consistently across the scope.
Gather the underlying records from the source systems and case files: keep the documents that support the count of convictions, the count of sanctions, and the total amount of fines in euros.
Compile the reported values in the required form: provide the two counts as numbers and the fine total as a euro amount, using one consistent basis across the disclosure.
Record any exclusions, adjustments, or changes in method: explain what was left out, what changed from the prior period, and why the reported figures differ from earlier submissions if that applies.
Check the draft against the official source and internal records: confirm the numbers tie back to the evidence, the scope is complete, and the final wording matches the underlying requirement without adding anything extra.
Request the data
Request the corruption case metrics from Legal / Secretariat
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How many corruption or bribery cases in the period ended in a conviction, a sanction, or a financial penalty, and what was the total amount of fines in euros?
Use your organisation’s own case-handling terms first, then map them to the reporting fields. For example, if you track matters as investigations, enforcement actions, settlements, or court outcomes, keep those labels in the request and ask the owner to translate them into the reporting view before sign-off. This is a training template only; adapt it to your organisation and check the source disclosure before sign-off.
Weak request
Please provide the ESRS G1-4 corruption and bribery metrics for the period, including convictions, sanctions and fines, in line with the disclosure.
Why it fails: It uses framework language instead of the organisation’s own case terms, does not say which register or system to pull from, and leaves the counting basis and currency treatment unclear. That makes it hard for the owner to know what to extract and how to map it.
Better request
Please provide the [period] case outcome data from your [legal case tracker / compliance register] for the [boundary]. We need the number of matters that ended in a conviction, the number that ended in a sanction, and the total fines in euros. Please keep your normal case labels in the extract and add a short mapping note so we can translate them into the reporting view.
Formal email template
Subject: Data request for corruption case outcomes and fines Dear [name/team], Please could you provide the case outcome data for [reporting period] for the [group/boundary]? We need the figures for matters that ended in a conviction, a sanction, or a fine, together with the total fine amount in euros. Please use your normal case labels in the first instance, and include a short mapping note so we can translate them into the reporting view. If any items sit outside your main register, please note where they came from. Could you return the data in the table below, plus the supporting evidence list, by [date]? Many thanks, [preparer name] [role] Training note: this is a possible LRA template only. Adapt it to your organisation and check the source disclosure before sign-off.
Short Teams / Slack version
Hi [name] — could you send over the [period] corruption/bribery case outcomes for [boundary]? We need counts for convictions, sanctions, and the total fines in euros. Please use your usual case labels and add a quick mapping note so we can translate them for reporting. Thanks — [name]
Industry examples
Financial services
Context. The organisation tracks enforcement matters, regulatory actions, and court outcomes in a central compliance log.
Adapted request. Please pull the [period] enforcement and court outcome data from the compliance log for [boundary]. We need counts for matters that ended in a conviction, a regulatory sanction, and the total fines in euros. Please keep the internal labels used in the log and add a mapping note for any items that need translation.
Example response. Returned table includes case ID, internal matter type, outcome date, jurisdiction, outcome label, conviction flag, sanction flag, fine amount in original currency, EUR equivalent, and source document reference.
Construction / infrastructure
Context. The organisation records legal claims and regulator actions in a project risk register and a legal matters tracker.
Adapted request. Please share the [period] legal matters extract from the project risk register and legal tracker for [boundary]. We need the number of cases that finished with a conviction, the number that ended with a sanction, and the total fines in euros. Please use the project/legal labels you already track and note how each item maps to the reporting view.
Example response. Returned table includes matter ID, project name, internal label, final outcome, decision date, authority/court, count status, fine amount, currency, EUR amount, and evidence reference.
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 how each figure was counted, what was included in the totals, and the reporting period and scope used to compile the three measures.
Context note
Explain what the counts and euro total indicate about enforcement activity in the period, and whether the monetary amount reflects a small number of large cases or many smaller ones.
Fluctuation statement
If the figures moved materially, describe the main drivers, such as changes in case volume, case severity, timing of decisions, or one-off events that affected the totals.
Content index entry
G1-4 Corruption & Bribery Metrics — [location / page] / [notes]Download Centre
Preparation tools & forms
Professional preparation tools for G1-4 — 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.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We separated out the number of court findings and regulatory penalties linked to bribery or corruption matters for the period, using a clear cut-off date and a single counting rule. | The assurer will check whether the two categories were kept distinct, whether the period boundary was applied consistently, and whether the counting method could double-count the same case. | Case log or incident register; legal/compliance tracker; period-end extraction showing the cut-off date; documented counting methodology; reconciliation from source cases to the published totals. |
| We included only matters that met our internal definition of a bribery or corruption breach, and we applied that definition consistently across all business units before aggregating the figures. | The assurer will probe whether the inclusion criteria were applied consistently, whether any borderline cases were excluded or included without justification, and whether the scope was complete. | Written inclusion criteria; review notes for borderline cases; business-unit submissions; consolidation workbook; sign-off showing the same rule set was used across the group. |
| We based the published numbers on source records held by legal, compliance, and finance, and we checked that each reported item could be traced back to supporting documentation. | The assurer will look for traceability from the published figure to underlying records and will test whether the source files are complete, authentic, and aligned to the final output. | Underlying notices, judgments, settlement letters, or penalty records; finance postings where relevant; traceability schedule; document index; evidence of file retention and version control. |
| Before publication, we reviewed the draft figures against the underlying case files and resolved any mismatches between local records and the consolidated disclosure. | The assurer will assess whether pre-publication checks were performed, whether discrepancies were investigated, and whether the final numbers reflect the corrected source data. | Draft-to-final comparison; review checklist; discrepancy log and resolution notes; approval emails or sign-off memo; evidence of corrections made before release. |
| Where a matter involved more than one outcome, we recorded each outcome separately and checked that the total amount reported for monetary penalties matched the supporting finance records. | The assurer will test whether outcomes were classified consistently, whether the monetary total is complete, and whether the amount agrees to the accounting or payment evidence. | Matter-by-matter schedule; penalty calculation support; payment confirmations or ledger extracts; reconciliation to finance records; reviewer sign-off on the final total. |
Evidence pack to prepare
Common reporting gaps
Units are missing or inconsistent across the figures.
The reporting scope or boundary for the numbers is unclear.
Estimates are not distinguished from measured values.
Parts of the total are double-counted or omitted.
Restatements of prior-period figures are not disclosed.
The calculation method or data source is not documented.
Common gaps
Mistakes to avoid when collecting the data
Wrong ownerSending the request to a team that only sees part of the case file means the count is built from incomplete records.
Framework words, not business termsAsking for the figures in disclosure language instead of the organisation’s own case labels makes people pull the wrong dataset or miss relevant entries.
Unclear boundaryNot stating which entities, sites, or case types sit inside the scope leads to some records being left out and others being counted twice.
Wrong time basisUsing a different reporting window from the one used in the source records produces totals that do not match the period being reported.
Mixed counting methodCombining case counts, people counts, and monetary amounts in one extraction step creates numbers that cannot be reconciled back to the source.
Source labels lostCopying the figures without keeping the original case IDs, file names, or ledger tags makes it impossible to trace each number back to its origin.
Populations mergedPutting convictions, penalties, and fine amounts into one undifferentiated list hides which figure belongs to which measure.
No evidence trailCollecting the numbers without the supporting extract date, owner, and approval record leaves no audit trail for later review.
No sign-off recordFailing to capture who checked the figures and when means the final set cannot be shown as reviewed before it is used.
Where judgement is often needed
What counts as a case in the reporting perimeter after a buy or sell transactionDecide whether to include outcomes linked to businesses added or removed during the year, explain the cut-off date used, and make clear if prior-period figures were restated or left as reported.
How to handle local legal labels that do not line up neatly across countriesUse one internal rule for classifying court outcomes, penalties and monetary penalties across jurisdictions, then disclose any country-by-country mapping or simplification you used so readers can see how unlike labels were made comparable.
Whether to include people or entities close to the boundary of controlSet out whether you counted matters involving joint ventures, contractors, agents or other connected parties, and explain the practical test used to decide when a case sits inside or outside the group’s own figures.
Choosing the date basis for the annual countState whether you used the date of the final decision, the date the matter was recorded, or another consistent point in time, and keep that basis the same for convictions, penalties and fines.
Using actual records versus estimates where the file is incompleteIf some cases are still being confirmed, explain whether you relied on measured amounts, management estimates or later adjustments, and identify which figures are provisional and which are final.
Rounding and presentation of small numbersExplain the rounding rule applied to counts and euro amounts, especially where a small number of cases or a low total fine could change materially after rounding, and keep the method consistent across the table.
Protecting personal data when the case list is very smallWhere naming or splitting the data would risk identifying individuals, aggregate the figures to a safer level and say that privacy protection affected the way the numbers were grouped.
Deciding whether one matter can lead to more than one metric entryClarify your rule for cases that end in both a conviction and a penalty, or in several penalties from the same matter, so users can see whether the counts and euro total reflect each outcome separately or only once.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Consumer goods
: during the reporting period, we recorded 3 convictions and 5 sanctions linked to business conduct matters, with total fines of €420,000. This example is internally consistent and shown for training purposes only.
Shows how to present the count of convictions, the count of sanctions, and the combined monetary amount of fines in a concise quantitative note.
Illustrative conduct outcomes for the period (count / €)
| Measure | Count |
|---|---|
| Convictions | 3 |
| Sanctions | 5 |
Illustrative (synthetic) example — Industrial manufacturing
: in our group, the period included 1 conviction and 2 sanctions, and the related fines came to €75,000. The figures below are illustrative, internally consistent, and provided for practitioner training.
Shows the same three data points for a different reporter and sector, using a separate synthetic fact pattern.
Illustrative conduct outcomes for the period (count / €)
| Measure | Count |
|---|---|
| Convictions | 1 |
| Sanctions | 2 |
Company reports
How companies report G1-4 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Covivio
Real Estate · France · 2025
Covivio’s 2025 Sustainability Report states that the company had zero convictions and zero fines related to violations of anti-corruption and anti-bribery laws, as noted on page 184. The report also references governance measures under the Sapin 2 law and mentions a review of corruption and influence peddling processes conducted in 2024 (pp. 179, 183). However, no specific numeric data or further details on anti-corruption policies or outcomes beyond these points were found in the report.
Continental AG
Tires · Germany · 2025
Continental AG's 2025 Annual Report provides a numeric value indicating zero convictions for corruption and bribery, as well as zero fines for violations of anti-corruption laws, reported on page 208. The report also references management approaches and metrics related to prevention and detection of corruption and bribery on pages 205–207 and 214. However, no additional numeric data or detailed findings on anti-corruption measures or outcomes were found elsewhere in the report.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj's 2025 Annual Report includes a statement on its zero tolerance policy towards bribery and corruption (p.131) and mentions confirmed incidents of corruption or bribery (p.135). The report also references fines related to violations of anti-corruption and anti-bribery laws (p.84). However, no specific numeric values or detailed quantitative data on these incidents or fines are provided in the report.
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Scenarios to work through
A group’s legal team confirms that one overseas subsidiary was convicted in the reporting year for a bribery-related offence, and a separate regulator issued a financial penalty in the same year for a different anti-corruption breach. The finance team is preparing the year-end disclosure and has to decide how to count each outcome.
QHow should the team treat the conviction and the penalty when completing the corruption-and-bribery metrics for the year?
Reveal model answer →Hide answer ↑
Count the court conviction as one conviction and the regulator’s penalty as one sanction, because they are different outcome types and each is tallied separately. If the same case led to both a conviction and a sanction, each outcome would still be counted in its own line, but the team should avoid double-counting the same outcome within a single metric. The figures should reflect the reporting period only and be supported by the underlying case records.
Why this matters · Separate legal outcomes by type, and count each outcome once in the correct metric.
A preparer has two matters on file: one ended with a conviction and a fine, while the other ended with a warning letter and no court case. The draft note currently lists both matters under the same heading because both relate to bribery concerns.
QShould both matters be rolled into one figure, or should they be split across the different data points?
Reveal model answer →Hide answer ↑
They should be split. The conviction belongs in the conviction count, the warning letter is not a conviction, and only a true sanction should feed the sanctions count. The fine from the convicted case is included in the monetary total only if it is a fine linked to the relevant anti-corruption outcome being reported, and the team should keep the mapping clear so each number matches the right category.
Why this matters · Use the nature of the outcome, not the topic of the case, to place each item in the right count.
During consolidation, one business unit reports a bribery conviction in local currency and another reports a sanction with no monetary amount attached. The group reporting team is unsure whether to leave the euro total blank until all subsidiaries have replied.
QWhat should the team do if there is a conviction or sanction but no fine amount is available for one of the cases?
Reveal model answer →Hide answer ↑
The team should still report the counts for convictions and sanctions based on the confirmed outcomes, but only include a euro amount where there is an actual fine to total. If a case produced a sanction without a fine, it contributes to the sanctions count but not to the euro figure. The monetary line should be the sum of the fines that are known and relevant, converted and presented consistently in euros.
Why this matters · Counts and money totals are related but not identical; a case can affect one line without affecting the other.
A sustainability analyst finds an internal spreadsheet showing three bribery-related court outcomes, but one was overturned before the reporting date and another was still under appeal at year-end. The draft disclosure currently includes all three because they were all mentioned in incident logs.
QWhich outcomes should be included in the year-end metrics, and why?
Reveal model answer →Hide answer ↑
Only outcomes that are confirmed for the reporting period should be included in the counts and the fine total. An overturned matter should not stay in the tally, and an unresolved appeal should not be treated as a final conviction or final sanction unless the reporting basis used by the organisation clearly supports that treatment. The analyst should rely on the final case status at the reporting date and keep the evidence trail clear.
Why this matters · Base the disclosure on the final status at the reporting date, not on early incident logs or provisional labels.
Framework references
Relevant ESRS requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
ESRS
G1-4
within ESRS G1: Business Conduct
Related & explore
Policies (Business Conduct) → CardActions (Business Conduct) → CardTargets → CardPolitical Influence & Lobbying → CardPayment Practices → Card
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FAQ
Questions this page answers
For G1-4, what data do I need to collect before I start drafting the disclosure?+−
The page says to prepare three datapoints: conviction count, sanction count and total fines amount. Use the step-by-step preparation section to turn those into a draft and keep the evidence pack ready for review.
How should I define the scope for G1-4 business conduct data on this page?+−
Use the page’s plain-language explainer and preparation steps to decide what sits in scope before you collect figures. The page does not set a formal scope rule, so you need to apply the guidance consistently and document your approach.
Who should own the G1-4 conviction, sanction and fines data in my organisation?+−
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source, check and explain the figures. The workbook is there to help assign and track those responsibilities.
What evidence should I keep to make a G1-4 disclosure assurance-ready?+−
The page includes an evidence pack with five items and five assurance claims to verify, each framed around claim, risk and evidence. Use those together so you can show where each number came from and how it was checked.
What are the five assurance claims on the G1-4 page and how do I use them?+−
The page says there are five claims to verify, each linked to a risk and evidence point. In practice, use them as a checklist to test whether the disclosure is complete, accurate and supported before it goes into a report.
What are the common mistakes to avoid when reporting G1-4?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot issues before drafting. Use that section to check for missing datapoints, weak evidence or inconsistent treatment across the disclosure.
How do I use the G1-4 workbook download to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track evidence and support the step-by-step preparation process.
What is the printable Library Card PDF for G1-4 used for?+−
The Download Centre includes a printable Library Card in PDF format. It is there as a practical reference alongside the workbook, so you can keep the key preparation and assurance points to hand while drafting.
Can I use the synthetic example on the G1-4 page to draft my own disclosure?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table, to show how the disclosure can be presented. Treat it as a format guide only and make sure your own numbers and narrative match your actual evidence.
How do I turn G1-4 data into a draft narrative and content-index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those prompts to turn the prepared figures into a clear draft, then check it against the evidence pack and assurance claims.
More questions this page can help with
G1-4 conviction count, sanction count and total fines amount: what should I gather first?How do I build an evidence pack for G1-4 business conduct disclosure?What should I check before sending a G1-4 disclosure for assurance review?How do I use the step-by-step how to prepare section for G1-4?What does the G1-4 plain-language explainer help me decide?How do I avoid common reporting gaps in G1-4?What is included in the G1-4 Prep & Assurance workbook download?How do the synthetic illustrative examples on G1-4 show the disclosure format?Where can I find real company report examples for G1-4?How do I use the G1-4 content-index line in a draft report?What should an ESG manager ask a data owner for when preparing G1-4?How do I use the assurance claims, risks and evidence on the G1-4 page together?
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