Disclosure focus
The practical focus is on completeness and consistency: readers should be able to see if the organisation has a joined-up approach for employees and other workers in its own operations, rather than a policy that exists only on paper or only at flagship sites. It is also useful to show where policies differ by geography, contract type or role, and how the organisation ensures they are actually applied in day-to-day management.
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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Forced labour flag
Human rights / complianceRecord whether the organisation identifies any forced labour issue for the reporting period, using a clear yes/no decision based on the evidence reviewed.
Evidence Human rights due diligence findings, audit results, grievance logs, investigation records, and management sign-off on the final yes/no.
Watch for The yes/no is set from an unreviewed allegation log rather than the investigation outcome, so the reported answer does not reconcile to the case file.
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Child labour flag
Human rights / complianceRecord whether the organisation identifies any child labour issue for the reporting period, using a clear yes/no decision based on the evidence reviewed.
Evidence Human rights due diligence findings, supplier audit results, grievance logs, investigation records, and management sign-off on the final yes/no.
Watch for The yes/no is taken from a supplier screening list rather than the confirmed case outcome, so the reported answer does not reconcile to the investigation record.
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Trafficking flag
Human rights / complianceRecord whether the organisation identifies any trafficking issue for the reporting period, using a clear yes/no decision based on the evidence reviewed.
Evidence Human rights due diligence findings, incident reports, grievance logs, investigation records, and management sign-off on the final yes/no.
Watch for The yes/no is based on a broad modern-slavery category rather than the specific trafficking assessment, so the datapoint is a definition mismatch.
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Policy title
Policy / legalCapture the exact title used for the relevant policy document that addresses the topic, as approved and in current use.
Evidence Approved policy register, document control record, intranet copy, or board/management approval pack showing the current policy title.
Watch for The name is copied from a draft or local variant rather than the approved policy register, so the title does not reconcile to the controlled document.
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Policy coverage group
Policy / HRState which worker groups the policy applies to, using the organisation’s own coverage wording for employees, non-employees, or both.
Evidence Policy scope section, HR policy matrix, contractor governance documents, and any published policy statement showing who is covered.
Watch for Employees and contractors are mixed up, so the stated coverage does not match the policy’s actual scope.
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Covered workforce groups
HR / policyList the workforce segments the policy covers, using the organisation’s defined segments rather than a generic workforce label.
Evidence Policy scope matrix, workforce segmentation map, HR/contractor population definitions, and the approved policy text.
Watch for A segment such as agency staff, contractors, or temporary workers is omitted because the list was copied from the HR headcount view rather than the policy scope.
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Policy aims
Policy / sustainabilityCapture the stated aims or intended outcomes of the policy, as written in the approved document and used internally.
Evidence Approved policy text, policy summary deck, board or committee paper, and any implementation plan that restates the policy aims.
Watch for The objectives are lifted from an implementation plan rather than the approved policy, so the stated aims do not reconcile to the source document.
Before you start
- Have you settled the exact policy title you will use, and is it the same label used in your internal records?
- Before drafting, have you decided whether this policy covers only employees, or also people who work for you in other ways?
- Have you identified which parts of the workforce are actually covered, so you do not mix the full headcount with a narrower group?
- Can you point each answer back to a source document or system record, so the figures and wording are traceable?
- Have you fixed the time basis for the information you are using, so the policy details match the period you are reporting on?
- Have you checked whether the policy addresses forced labour, child labour and trafficking separately, so each yes/no answer is based on the right internal source?
How to prepare it
Request the data
Request the workforce policy details
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which people policy applies to our workforce, and what does it cover?
Use your organisation’s own policy names and people-team language first, then map them to the disclosure fields. Do not ask for the framework labels in the first instance; ask for the internal policy record, the groups it covers, and the stated aims. Check the source material before sign-off.
Weak request
Please provide the ESRS S1:S1-1 policy disclosures for own workforce, including the policy name, scope, workforce segments, objectives, and whether it covers forced labour, child labour, and trafficking.
Why it fails: This uses framework language first, which can slow down the response and create translation errors. It also does not point the owner to the internal policy record, the usual document name, or the business groups they actually manage.
Better request
Please send the current people policy record for our workforce: the policy title and version, who it applies to, which worker groups and business areas it covers, its main aims, and whether it addresses forced labour, child labour, and trafficking. Include the document location and review date. We will map your internal terms to the reporting fields afterwards.
Formal email template
Subject: Request for people policy details for reporting Hi [Name], We are preparing the reporting pack and need the current details for the policy that covers our workforce. Please send: - the policy name and current version - the groups of workers it applies to - the parts of the workforce it covers - the main aims of the policy - confirmation of whether it addresses forced labour, child labour, and trafficking - the period / version date and where the document is stored If there are separate policies for different worker groups, please include each one and note which groups they cover. Please use your team’s usual policy names and categories. We will map them to the reporting fields after we receive them. This is a training template only; please adapt it to your organisation and check the source material before sign-off. Thanks, [Your name]
Short Teams / Slack version
Hi [Name] — could you share the current people policy details for the reporting pack? Please send the policy name/version, who it covers, which worker groups are in scope, the main aims, and whether it covers forced labour, child labour, and trafficking. Also include the document location and review date. Use your team’s usual terms first; we’ll map them afterwards. This is a training template only — please adapt it to your organisation and check the source material before sign-off. Thanks, [Your name]
Industry examples
Manufacturing
Context. A site-based employer with permanent staff, agency labour, and apprentices.
Adapted request. Please share the current site people policy details for the reporting pack: the policy name/version, which worker groups it covers, whether it applies to employees, agency workers, and apprentices, the main aims, and whether it addresses forced labour, child labour, and trafficking. Include the document location and review date. Use your site and people-team terms first; we will map them afterwards. This is a training template only — please adapt it to your organisation and check the source material before sign-off.
Example response. Policy: Site Workforce Standards Policy v3.1; Coverage: employees, agency workers, apprentices; Areas: production sites and warehouse operations; Aims: safe conduct, fair treatment, reporting routes; Forced labour: Yes; Child labour: Yes; Trafficking: Yes; Location: People policy library; Review date: 12 Feb 2025
Professional services
Context. A services business with employees, contractors, and interns across multiple offices.
Adapted request. Please send the current people policy details for the reporting pack: policy title/version, who it covers, which groups are in scope across offices, the main aims, and whether it addresses forced labour, child labour, and trafficking. Include the document location and review date. Please use your internal policy names and worker categories first; we will map them afterwards. This is a training template only — please adapt it to your organisation and check the source material before sign-off.
Example response. Policy: Workplace Conduct and Engagement Policy v2.0; Coverage: employees, contractors, interns; Areas: all offices and remote workers; Aims: set conduct expectations, protect workers, define escalation routes; Forced labour: Yes; Child labour: No; Trafficking: Yes; Location: Intranet policy hub; Review date: 30 Sep 2025
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
We based this draft on the organisation’s named policy, the worker groups it is meant to cover, the workforce segments included, and the stated aims, using the collected yes/no flags for the three labour-related risk topics.
Context note
These figures show the organisation’s formal coverage of labour-related risks and which parts of the workforce the policy is intended to reach, rather than evidence of incidents or outcomes.
Fluctuation statement
If the coverage or stated aims changed from the prior period, the reporter can explain that the shift reflects a revised policy scope, a broader or narrower set of worker groups, or updated objectives.
Content index entry
S1-1 Policies (Own Workforce) — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S1-1 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We updated the policy set during the year and can show what changed, when it changed, and who approved it.
Risk An assurer will test whether the reported change is real, dated, and limited to the period claimed, rather than a later edit or a general statement of intent.
Evidence to check Version history, redline or tracked-change copies, approval papers, board or management minutes, publication dates, and the final issued policy text.
We took account of views from the people affected when shaping the policy content.
Risk An assurer will probe whether stakeholder input was actually considered, or whether the statement is unsupported or based on a narrow internal view only.
Evidence to check Consultation notes, meeting records, survey outputs, grievance or worker-feedback summaries, analysis showing how feedback influenced the policy, and sign-off papers.
We can point to the policy sections that set out its purpose, what it covers, what it leaves out, and which groups it is meant to protect.
Risk An assurer will check whether the policy really contains those elements and whether the disclosed scope matches the underlying document without overstating coverage.
Evidence to check The policy document itself, scope statements, exclusion clauses, mapping to affected groups, and internal review notes confirming the disclosed summary.
We have identified each relevant policy and can show the main rules it contains, the aim it is meant to achieve, and the material issues it is linked to.
Risk An assurer will test whether the disclosure is complete, whether the policy descriptions are accurate, and whether the link to material issues is evidenced rather than inferred.
Evidence to check Policy register, policy texts, materiality or impact assessment papers, cross-reference matrix, and review/approval records.
Where a policy refers to outside principles or initiatives, we have the source documents and can show the exact commitments we made.
Risk An assurer will check that any external reference is specific, current, and not overstated, and that the policy really commits to it.
Evidence to check Policy wording, copies or links to the referenced principles or initiatives, legal or sustainability review notes, and approval evidence.
We can show the overarching rights policy, where it sits in the policy set, and which groups it is intended to cover.
Risk An assurer will probe whether the policy exists as described, whether the coverage statement is consistent across documents, and whether the named groups are supported by the source material.
Evidence to check Policy hierarchy documents, the overarching policy text, scope and audience statements, group definitions, and sign-off records.
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 owner askedThe team chases the policy owner in the wrong function, instead of the people who actually keep the staff policy register and can confirm the current version.
- Framework language used too earlyThe request goes out in ESRS-style wording, so the business cannot map it to its own policy names, workforce groups, or internal labels.
- Scope not pinned downNo one states whether the policy applies to employees only or also to other workers, so the data pull mixes the wrong populations.
- Coverage groups blurred togetherDifferent staff segments are merged into one answer even though the source records them separately, which hides where the policy really applies.
- Wrong time basis usedThe collector asks for the position at the wrong date or period, so the answer reflects an out-of-date policy set rather than the reporting cut-off.
- Counting basis mixed upOne source counts policies by document, another by topic or business unit, and the final extract combines them without aligning the basis first.
- Source labels lostThe original file names, register codes, or system tags are dropped during extraction, making it impossible to trace each answer back to the underlying record.
- Evidence trail incompleteThe pack is assembled without the supporting note, version history, and sign-off record, so nobody can show who checked the data and when.
Judgement needed
- Defining the policy name when several documents cover the same topicUse one clear label for the main rule-set you rely on, and if related documents sit alongside it, explain how you grouped them so readers can tell what sits inside the same policy family.
- Deciding who counts as part of the workforce scopeState whether you include only direct staff or also people working for you through other arrangements, and explain any cut-off used for groups that sit near the boundary.
- Handling different country terms for the same worker groupWhere local employment labels do not map neatly across locations, describe the practical rule you used to place each group into your chosen categories and note any exceptions.
- Setting the coverage line after a buy-in or saleIf the reporting perimeter changed during the period, explain from which date the new or removed teams were brought into or taken out of the policy coverage view.
- Choosing which parts of the workforce are covered by each topicFor each subject area, spell out which employee groups and other workers are included, and make clear when a topic applies only to some segments rather than everyone.
- Describing aims in a way that matches how the business actually manages people risksLink each stated aim to the practical people-risk or conduct issue it is meant to address, and avoid broad wording that does not show what the policy is trying to change.
- Using estimates where the underlying records are incompleteIf you cannot trace every group directly from source records, say which figures were estimated, what basis was used, and how you kept the approach consistent across the report.
- Rounding and small-number presentationExplain the rounding rule you applied and make sure any totals still reconcile after rounding, especially where small groups could otherwise be hidden or overstated.
- Protecting privacy when the workforce is too small to show in detailWhere a breakdown could identify individuals, combine categories or suppress detail as needed, and say that the presentation was adjusted to avoid exposing personal information.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We maintain a modern slavery and labour-rights policy that applies to our own staff and to contractors, agency workers and other business partners in our supply chain. It covers production, warehousing, logistics and procurement teams, and its aim is to prevent exploitative recruitment, protect younger workers and strengthen oversight of high-risk sourcing.
- In the reporting period, we did not identify any forced labour, child labour or trafficking cases in our operations or value chain.
- The policy is applied across employees and non-employees, with coverage for permanent staff, temporary workers, agency labour, transport providers and key suppliers.
This synthetic example shows how to describe the policy, who it applies to, which parts of the workforce it reaches, and the three labour-exploitation flags in a concise narrative form.
Our code on fair work and responsible sourcing sets the rules for our own people and for selected external workers who support software delivery, data operations and facilities management. It is designed to reduce the risk of coercive recruitment, stop under-age work and trafficking, and improve checks on labour practices in higher-risk service contracts.
- During the period, we recorded no confirmed instances of forced labour, child labour or trafficking.
- The coverage extends to employees and non-employees, including full-time staff, fixed-term staff, contractors, outsourced support teams and on-site service providers.
This synthetic example uses a different sector and wording while still covering the policy title, who is in scope, which worker groups are included, the policy aims, and the three yes/no labour-risk indicators.
Quality ladder
- Basic
We have a policy for our own workforce.
- Better
We have a named policy for employees and contractors that covers permanent staff, agency workers and apprentices, and it aims to prevent forced labour, child labour and trafficking.
- Best
We use our Own Workforce Conduct Policy across employees and non-employees, covering permanent staff, agency workers and apprentices, and we reviewed it this year because we expanded contractor oversight after a small rise in outsourced roles.
Check your understanding
Scenarios to work through
A group HR lead is drafting the people policy summary for the annual report. The document covers permanent staff and agency workers, but the draft title only mentions employees, and the team has not yet checked whether the wording matches the actual policy scope.
A preparer has one internal code of conduct for all staff, but separate contractor rules sit in a procurement folder. They are unsure whether the disclosure should mention only the staff code or also the contractor rules when describing the workforce covered.
The sustainability team has a draft policy that bans forced labour and child labour, but the section on trafficking is still being reviewed by legal. The team wonders whether they can leave trafficking out for now and add it later if the wording is finalised before publication.
A company has a broad human rights policy for its own workforce, but the report draft only says it promotes fair treatment and safe working conditions. The team has not yet stated what the policy is trying to achieve for workers or how it links to the labour-abuse topics.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
S1-1
within ESRS S1: Own Workforce
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page also gives draft-output prompts, so you can turn the collected information into a first-pass narrative and content line.
The page says to prepare the forced labour, child labour and trafficking flags, plus the policy title, policy coverage group, covered workforce groups and policy aims. Use those items as your minimum data set before drafting.
Use the page’s coverage fields to set scope in practice: policy coverage group and covered workforce groups. That helps you show which parts of the workforce the policy applies to before you draft the disclosure.
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can confirm the policy details and workforce coverage. The workbook and evidence pack are there to support that handover and review.
The page includes six assurance claims to verify and an evidence pack with five items for assurance readiness. Use those to build a file that links each claim to the supporting source material before review.
The page has a section on common reporting gaps and mistakes, so use that as a pre-submission check. It is especially useful for spotting missing datapoints, unclear scope, or weak evidence before you finalise the draft.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the required datapoints, track the assurance claims and evidence, and move from raw inputs to a draft disclosure.
The Download Centre also includes a printable Library Card in .pdf format. It is useful as a quick reference while you gather data, check the preparation steps, and review the draft output.
Yes, it includes synthetic illustrative example disclosures, including a quantitative table. Treat them as examples of structure and presentation only, and make sure any real draft stays consistent with your own data.
The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those prompts to convert the prepared datapoints into a clear first draft and a simple index reference.
More questions this page can help with