Disclosure focus
The practical question is how far those policies apply and how they are used across the business. An organisation should make clear whether the policies cover the whole group, specific business units, regions or operations, and whether they apply consistently or only in certain areas. If coverage is limited, the organisation should explain the scope and any important exclusions so readers can understand the real extent of implementation.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Policy title
Policy owner / Legal / ComplianceRecord the exact title used for the policy in the organisation’s current documents.
Evidence Approved policy register, intranet policy page, or signed policy document.
Watch for The title does not match the version held in the policy register or approved document set.
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Policy purpose and scope
Policy owner / Sustainability / ComplianceSummarise the main aims and the core points the policy is meant to achieve or cover.
Evidence Policy text, board paper, or internal guidance note that sets out the policy’s purpose and main provisions.
Watch for The summary mixes up objectives with procedures, or omits a stated aim from the source policy.
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Linked impact topic
Policy owner / Risk / SustainabilityState the impact, risk or opportunity area that this policy is intended to address.
Evidence Policy rationale, risk register, or sustainability issue mapping that links the policy to the relevant topic.
Watch for The stated link is to the wrong issue category, so the policy is mapped to an unrelated impact or risk.
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Policy changes this year
Policy owner / Legal / ComplianceCapture any changes made to the policy during the reporting period, including updates, rewrites, or removals.
Evidence Version history, tracked changes, approval papers, or change log for the period.
Watch for The period is wrong, with changes from outside the reporting window included or in-period updates missed.
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Policy coverage limits
Policy owner / Legal / ComplianceDescribe which parts of the business, activities, locations, or entities the policy applies to, and any explicit exclusions.
Evidence Policy scope statement, applicability matrix, or group policy framework showing inclusions and exclusions.
Watch for The scope is overstated or understated because a business unit, geography, or excluded entity is not aligned to the source policy.
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External standards used
Policy owner / Compliance / Technical ownerList any outside standards, codes, or frameworks the policy says it relies on or follows.
Evidence Policy references section, annexes, or linked standards register.
Watch for A referenced standard is missing, or an internal guideline is reported as if it were an external standard.
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Social input considered
Sustainability / Social impact / Stakeholder engagementCapture how relevant stakeholder views were taken into account when setting policy on social matters.
Evidence Consultation notes, engagement summaries, employee or community feedback logs, and policy approval papers.
Watch for A stakeholder group is left out, so the evidence reflects only one audience rather than the social topics actually considered.
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Human rights policy flag
Legal / Compliance / SustainabilityConfirm whether the organisation has a policy specifically covering human rights.
Evidence Policy inventory, approved policy list, or governance attestation showing yes/no status.
Watch for The yes/no answer is based on a broad ethics or conduct policy rather than a policy that actually covers human rights.
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Covered stakeholder groups
Policy owner / Human rights / SustainabilityIdentify which groups the human rights policy applies to or is intended to protect.
Evidence Policy text, scope statement, or stakeholder coverage matrix.
Watch for A covered group is omitted, or a group is included even though the policy does not actually name or cover it.
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Human rights standards cited
Policy owner / Legal / ComplianceList the human rights-related standards, principles, or codes the policy refers to.
Evidence Policy references, annexes, or compliance library showing the cited standards.
Watch for The cited standard is the wrong one, or a local code is reported as if it were a human rights standard.
Before you start
- Have you fixed which policy or policies sit within the reporting boundary, and which parts are left out?
- For each policy, have you settled the main aims and the practical points you will describe in your own business language?
- Have you linked each policy to the relevant impact, risk or opportunity it is meant to address?
- If a policy changed during the period, have you decided what counts as a change and what date range you will use?
- Where a policy refers to outside rules or standards, have you checked exactly which ones you will name and whether they are still the right reference points?
- If the topic is social or human-rights related, have you decided which stakeholder groups are covered and whether you have a policy in place for that area?
How to prepare it
Request the data
Request the policy register and supporting evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which current policies, scope notes and related references do we need to evidence how the organisation manages its material sustainability topics?
Use your organisation’s own policy, governance and issue-management terms first, then map them to the reporting fields. Keep the request in the language the policy owner, legal team or company secretariat already uses, rather than framework labels.
Weak request
Please provide the ESRS 2:GDR-P policy disclosures, including the policy name, contents, related IRO, changes, scope, third-party standards, stakeholder consideration, and human rights policy details.
Why it fails: It uses framework language that many internal owners will not recognise, and it bundles several reporting labels without saying what practical evidence is needed. That makes it harder to answer quickly and increases the chance of incomplete or mismatched evidence.
Better request
Please send the current policy documents and a short table showing: the policy title, what it is meant to cover, which sustainability topic or issue it supports, what changed during the period, where it applies and any exclusions, any external principles or codes named, and for people-related topics which stakeholder groups were considered. If there is a human rights policy, include the policy itself and the groups it covers. Use your own internal terms first, then we will map them to the reporting pack.
Formal email template
Subject: Request for policy evidence for [reporting period] Dear [name/team], We are preparing the sustainability reporting pack and need your help to collect the current policy evidence for [reporting period]. Please share the latest versions and any supporting records for the policies you own or maintain, together with the details below. For each policy, please provide: - policy title and current version - short summary of what it covers and the main aims - which sustainability topic(s), issue(s) or commitment(s) it is linked to - any changes made during the period - the parts of the business, entities or activities it covers, and any exclusions - any external principles, codes or standards named in the policy - for people-related topics, any stakeholder groups considered when the policy was set or updated - approval or sign-off evidence, where available - source link or document reference Please use your own internal wording first, then we will map it to the reporting fields. If there are multiple policies, please send them in a simple table. A possible LRA training template is attached below. Please adapt this to your organisation and check the official source before sign-off. Kind regards, [preparer name] [team] [contact details]
Short Teams / Slack version
Hi [name/team] — could you send the latest policy list and supporting evidence for [reporting period]? Please include the policy name, version, what it covers, any changes this year, scope/exclusions, linked sustainability topics, any external references named, and any approval record. Use your own internal terms first; we’ll map them later. A possible LRA training template is attached — please adapt to your organisation and check the official source before sign-off. Thanks, [name]
Industry examples
Manufacturing
Context. The business has site-level environmental procedures, a group code of conduct, and a supplier policy managed by Legal and Operations.
Adapted request. Please share the current group policies and site procedures that set out how we manage our main sustainability topics, including the policy name, what each one covers, any changes this year, which plants or entities it applies to, any exclusions, and any external codes or standards named. For people-related topics, include any worker or community input used when the policy was updated.
Example response. A table listing the Code of Conduct, Environmental Policy and Supplier Standards, with version numbers, approval dates, scope across all sites except one acquired plant, a note that the supplier policy was updated in Q3, and references to an external labour code and a responsible sourcing standard.
Financial services
Context. The business has conduct, lending, customer treatment and human rights policies owned by Legal, Risk and Compliance.
Adapted request. Please provide the current policy set that explains how we manage our material sustainability topics, including the policy title, summary of coverage, any changes during the year, business lines or entities in scope, exclusions, and any external principles or codes referenced. If there is a human rights policy, include the groups it covers and any standards named in it.
Example response. A table covering the Conduct Policy, Responsible Lending Policy and Human Rights Policy, with current versions, board approval dates, scope across retail and corporate banking, an exclusion for a discontinued product line, and references to an external human rights framework and a customer fairness code.
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 the policy information was compiled, including how each policy was named, how its purpose and related issue were identified, what counted as a change in the period, how scope limits and exclusions were treated, and which outside standards were noted.
Context note
Explain what the policy set shows about how the organisation manages its material impacts, risks and opportunities, including whether it has a formal human rights policy, which groups it considers, and whether it relies on external standards to shape its approach.
Fluctuation statement
If the policy set changed during the period, explain whether that was due to new issues, revised priorities, updated external references, or a broader change in coverage, and note any shifts in the groups or topics the organisation now addresses.
Content index entry
GDR-P Policies Adopted to Manage Material Sustainability Matters — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for GDR-P with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We prepared the coverage figure using the same basis across the period and checked that the policy summary matches the version approved for reporting.
Risk The assurer may find the figure or summary was built on an inconsistent basis, or that the reported wording does not match the approved policy document.
Evidence to check Approved policy register; version history; reporting pack showing the basis used; sign-off records linking the published wording to the approved source.
We included the main policy points for the human rights policy and kept the description aligned to the current approved text.
Risk The assurer may probe whether the human rights policy was described fully and accurately, or whether key elements were omitted or outdated.
Evidence to check Current human rights policy; board or management approval evidence; cross-reference table from policy clauses to the published disclosure; review notes confirming completeness.
We mapped each policy statement to the relevant business areas before publication so the disclosed coverage reflects the intended scope.
Risk The assurer may question whether the disclosure overstates or understates what the policy actually covers.
Evidence to check Scope mapping or coverage matrix; policy inventory; internal review comments; evidence of sign-off by the policy owner and reporting team.
Where a policy changed during the year, we updated the disclosure to reflect the revised position and retained evidence of what changed.
Risk The assurer may test whether changes were missed, misdated, or described in a way that does not match the actual revision history.
Evidence to check Change log; tracked revisions; approval dates; comparison between prior and current versions; meeting minutes or email approvals for the update.
We checked the stated scope and any exclusions against the underlying policy wording, including the parts of the business and locations it is meant to cover.
Risk The assurer may challenge whether exclusions were described too broadly or too narrowly, or whether the geography and operational coverage are unsupported.
Evidence to check Policy scope section; exclusion list; entity and location mapping; legal entity or operational boundary schedule; internal review sign-off.
We reviewed whether the policy applies to relevant stakeholder groups and used the same group definitions consistently in the disclosure.
Risk The assurer may ask whether affected groups were left out, grouped too loosely, or described in a way that is not supported by the policy.
Evidence to check Stakeholder mapping; policy wording on covered groups; consultation notes; internal consistency check between stakeholder register and disclosure text.
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe request goes to a policy team or sustainability lead when the facts sit with the business owner who actually runs the process and can confirm the current wording.
- Framework language firstPeople ask for answers in disclosure terms instead of the organisation’s own policy names, topic labels, and internal wording, so the source team cannot map the data cleanly.
- No clear boundaryThe team collects policy information without fixing which entities, sites, functions, or excluded parts are in scope, so the final set mixes covered and uncovered areas.
- Wrong timing basisThe data pull uses the wrong reporting window or a later approval date, so the record does not match the period being reported.
- Mixed counting basisDifferent teams count policies, topics, or references using different rules, which makes the totals and lists impossible to compare or reconcile.
- Source labels lostThe original file names, version tags, or document titles are stripped out during collection, so nobody can trace each answer back to the exact source used.
- Populations mergedSeparate groups that should stay distinct, such as different stakeholder sets or different policy types, are combined into one list and the detail is no longer usable.
- Missing evidence trailThe collector saves the answer but not the supporting note, extract, or approval record, so there is no audit trail showing where the information came from.
- No sign-off recordThe draft data is passed on without a named reviewer and date, so there is no clear proof that the business owner checked it before it moved forward.
Judgement needed
- What counts as a policy when the same topic is covered in several documentsChoose a clear rule for whether you describe one umbrella policy or several linked documents, and explain the basis so readers can see how the named policy, its main aims and the related issue are connected.
- How to handle policy wording that differs by country or business lineIf local rules or operating practices lead to different wording in different places, state the versioning approach and explain which wording you have used for the report and why it best reflects the group-wide position.
- Whether to include parts of the workforce or value chain that sit near the boundarySet out the inclusion rule for people or activities that are close to the reporting boundary, then explain any exclusions so readers can see who is covered and who is not.
- How to describe changes made during the periodIf a policy was updated, merged, retired or replaced during the year, describe the nature of the change and the timing, and make clear whether the current wording or the earlier version is being presented.
- How to treat acquisitions, disposals and other boundary shiftsWhen the group perimeter changes, explain whether the policy description follows the current structure or the prior one, and disclose any material additions or removals that affect the scope statement.
- Whether a third-party code or framework is being adopted in full or only in partIf you refer to an external standard, say whether it is used as a full reference point or only for selected parts, and identify any material departures in plain language.
- How to decide which stakeholder views are reflected for social topicsExplain which groups were considered, how their input was used, and where the policy reflects those views only in part, so the reader can see the practical basis for the social coverage.
- How to present human-rights coverage across different groupsState which worker or community groups are covered by the human-rights policy and explain any gaps, especially where one policy applies to some groups but not others.
- How to deal with estimates, rounding and privacy limits in the narrativeWhere exact detail cannot be shown because of estimation, rounding or confidentiality, say so and explain the method used, keeping the description consistent with the underlying records and the level of aggregation chosen.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We set out our policy on responsible sourcing and worker treatment, which aims to reduce labour-rights and supply-chain harm linked to our operations and key suppliers. During the period, we tightened supplier screening, widened the policy to cover two additional raw-material categories, and kept the same exclusions for minor office services and short-term contractors; we also note that our approach draws on recognised external frameworks and that we considered employee and community views when shaping the parts touching social issues.
- The policy applies across our owned sites and tier-1 suppliers, with the exclusions above.
- It refers to the recognised human-rights due-diligence expectations and the recognised responsible-business guidance.
- We also maintain a separate human-rights policy covering employees, agency workers, direct suppliers, and local communities, with the same external references.
This example shows how a reporter can describe the policy in plain language, identify the main issue it is meant to address, note what changed in the year, explain where it applies and what is left out, and name the outside frameworks used. It also shows a separate human-rights policy and the groups it covers.
Our climate-transition and community-impact policy explains how we manage transition-related disruption, local engagement, and fair treatment in project delivery. In the year, we added a requirement for contractor grievance logging, narrowed one legacy exemption for emergency works, and kept the policy focused on our generation assets, grid projects, and major contractors rather than small administrative services; the policy also cites external frameworks and reflects feedback from residents and workforce representatives on the social side.
- The policy covers our generation assets, grid projects, and major contractors, but not small administrative services.
- It draws on the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy and the recognised human-rights due-diligence expectations.
- We have a separate human-rights policy for employees, contractors, affected communities, and customers, with those same references.
This example demonstrates a different sector using the same disclosure points in a distinct way. It shows how to describe the policy’s purpose, the issue it relates to, changes made during the period, the boundaries and exclusions, the external references, and the stakeholder input used for social matters.
Quality ladder
- Basic
We have a policy for our material sustainability topics.
- Better
We have 12 policies covering our material sustainability topics, and each one names the main aim and the related impact, risk or opportunity it is meant to address.
- Best
We have 12 policies in place across our material sustainability topics, covering the parts of the business in scope and any exclusions, and this year we updated 3 of them because our risk review showed a shift in priorities and stakeholder feedback pointed to stronger focus on people-related issues.
Check your understanding
Scenarios to work through
A group policy on labour and community impacts was updated mid-year after a supplier audit found gaps in grievance handling. The draft report mentions the revised policy title and says it applies to direct operations, but it does not explain what changed or whether any sites were left out.
The sustainability team has a human rights policy that covers employees, agency workers and contractors, and it also refers to a supplier code based on an external labour standard. The draft report lists the policy and the external standard, but it does not say which stakeholder groups are covered or how the outside framework is being used.
A company has one policy for climate transition and another for community relations. The climate policy was unchanged this year, but the community policy was rewritten after stakeholder feedback. The draft report describes both policies in the same way and does not distinguish which one was shaped by stakeholder views.
A preparer is compiling the policy section and has a list of internal policies, but one of them is only a short statement with no objectives, no link to a material issue, and no mention of any outside standard. Another policy is a fuller document that includes all of those points. The team is unsure whether the short statement can be listed on its own.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
GDR-P
within ESRS 2: General Disclosures
Guides that settle this question
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FAQ
Questions this page answers
Start with the page’s datapoints to prepare: policy title, purpose and scope, linked impact topic, policy changes this year, coverage limits, external standards used, social input considered, human rights policy flag, covered stakeholder groups, and human rights standards cited. The page also gives a step-by-step preparation flow, so you can turn those inputs into a first draft rather than starting from a blank page.
Use it as a working checklist to move from scoping to drafting: identify the policy, confirm what it covers and excludes, gather supporting inputs, and then write the disclosure. The page is designed to help a practitioner prepare the disclosure in a structured way, not just describe it.
The page points you to policy-level inputs such as title, purpose, scope, changes this year, coverage limits, and the stakeholder and human rights information used to shape the policy. That makes it useful for assigning specific data owners to each field before drafting.
Use the page’s scope-related datapoints to state what the policy covers and where it stops, including any coverage limits. The common gaps section is there to help you avoid vague wording or implying broader coverage than your evidence supports.
The page includes an evidence pack with five items for assurance readiness, so you can assemble support for the policy details, the inputs used, and the draft disclosure. It is meant to help you build a reviewer-friendly file rather than rely on narrative alone.
The page lists six assurance claims to check, each framed around a claim, the related risk, and the evidence needed. Use those claims to test whether the disclosure is supported, complete, and consistent before it goes to review.
The page has a common reporting gaps and mistakes section that you can use as a pre-submission check. It is intended to help you spot missing scope detail, weak evidence, or other avoidable drafting issues before the disclosure is finalised.
Use the draft-output section to move from collected data to a usable draft, including narrative starters, a content-index line, and visualisation ideas. The page also includes synthetic illustrative examples, which can help you see how the data points fit together in practice.
Yes, but only as a pattern for structure and completeness, not as a template to copy. The examples are explicitly synthetic and the quantitative table is there to show how the data can be presented consistently.
The Download Centre provides a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise the preparation and evidence checks, and the card as a quick reference while drafting or reviewing.
It links to real published reports at the pages where the topic is disclosed, so you can see how companies have presented similar information in practice. It is a reference aid for drafting and review, not a statement of required wording.
More questions this page can help with