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London Reporting Academy ESRS S1 · Own Workforce · Disclosure Requirement S1-2

Applicable from FY2027

This revised ESRS edition applies from reporting year 2027. For reporting years 2024–2026, use the ESRS 2023 edition.

Engagement & Grievance Mechanisms

S1-2 · mandatory · coverage + narrative

This disclosure asks an organisation to explain how it engages with its own workforce and how people can raise concerns or complaints. In practice, the report should show whether workers have ways to speak up, whether those channels are available in a way that people can actually use, and how the organisation responds when issues are raised.

Disclosure focus

The practical focus is on coverage and accessibility across the organisation, not just on a few well-known sites or headquarters. A useful response should make clear whether the arrangements apply across operations, locations and worker groups, and whether there are differences in how they work in practice for different parts of the workforce.

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.

  • Engagement approach

    Sustainability / stakeholder engagement

    Describe the main ways the organisation consults or involves affected people and other relevant parties.

    Evidence Stakeholder engagement plan, consultation logs, meeting notes, survey records, community liaison records.

    Watch for Engagement channels are described differently from the actual consultation records, so the narrative does not reconcile to the engagement log.

  • Priority groups engaged

    Sustainability / stakeholder engagement

    List the specific groups the organisation has identified for engagement, including women, migrant groups and people with disabilities where relevant.

    Evidence Stakeholder mapping, inclusion lists, consultation participant records, community or worker group registers.

    Watch for A sub-population is missed or grouped differently, so the named groups do not match the stakeholder map.

  • Engagement methods used

    Sustainability / stakeholder engagement

    Set out the practical methods used to engage those groups, such as meetings, surveys, forums or other channels.

    Evidence Engagement calendar, consultation minutes, survey tools, workshop attendance lists, channel records.

    Watch for The method list is not aligned to the actual engagement records, so a channel used in practice is omitted.

  • Formal agreements in place

    Legal / HR / stakeholder engagement

    State whether there are formal arrangements with worker or community representatives covering engagement with those groups.

    Evidence Signed agreements, memoranda of understanding, collective arrangements, representative body records.

    Watch for The yes/no answer is based on informal practice rather than signed arrangements, so the status is misclassified.

  • Agreement subject matter

    Legal / HR / stakeholder engagement

    If such arrangements exist, describe what they cover in practical terms.

    Evidence Agreement text, annexes, scope notes, representative consultation terms.

    Watch for The scope is described too broadly or too narrowly, so the reported coverage does not match the agreement text.

  • Agreement coverage

    Legal / HR / stakeholder engagement

    Explain which people, sites, operations or activities are covered by those arrangements.

    Evidence Agreement schedules, site lists, workforce coverage notes, entity or location registers.

    Watch for Coverage is reported at the wrong entity or site level, so the population covered does not reconcile to the agreement schedule.

  • Reporting channels

    Compliance / ethics / HR

    Describe the channels available for people to raise concerns or complaints, including internal and external routes where applicable.

    Evidence Policy documents, hotline portal screenshots, intranet pages, supplier or worker handbooks, posters.

    Watch for A channel is described that is not actually live in the source system or handbook, so the published list does not match what users can access.

  • Grievance route exists

    Compliance / ethics / HR

    State whether a formal route exists for people to raise concerns and seek response.

    Evidence Grievance policy, complaints procedure, hotline setup records, case management system configuration.

    Watch for The yes/no answer is taken from policy wording rather than an active process, so the existence of the route is overstated.

  • Issues raised

    Compliance / ethics / HR

    Capture the number and nature of cases or complaints raised through the available channels during the reporting period.

    Evidence Case management system, hotline logs, complaints register, investigation tracker.

    Watch for Cases are counted outside the reporting period or from only one intake channel, so the case total does not reconcile to the complaints register.

  • Case closure rate

    Compliance / ethics / HR

    Report the share of raised cases that were closed or otherwise resolved in the period, using the organisation's chosen basis consistently.

    Evidence Case tracker, closure status report, complaints dashboard, resolution log.

    Watch for Closed cases and open cases are mixed across different cut-off dates, so the rate does not reconcile to the case tracker.

  • Channel effectiveness

    Compliance / ethics / HR

    Explain how the organisation judges whether the available channels work well in practice.

    Evidence Effectiveness review, user feedback, usage statistics, audit findings, management review notes.

    Watch for The assessment is based on anecdotal feedback only, so it does not reconcile to the underlying usage and outcome data.

  • Remedy process

    Compliance / ethics / legal

    Describe the process used to provide remedy when a case requires it, including how decisions are made and followed through.

    Evidence Remediation procedure, investigation workflow, corrective action process, case handling guidance.

    Watch for The process description does not match the actual case-handling workflow, so the stated remedy steps are not the ones used in practice.

  • Remedied cases

    Compliance / ethics / legal

    Capture the cases that were remedied during the period and the basis used to count them.

    Evidence Remediation log, case closure records, corrective action tracker, settlement or repair records.

    Watch for Remedied cases are counted without the same cut-off as the case log, so the total does not reconcile to closed remediation records.

  • Remedial actions taken

    Compliance / ethics / legal

    List the concrete actions taken to put things right for the cases that were remedied.

    Evidence Corrective action tracker, case notes, settlement records, repair or compensation records, follow-up evidence.

    Watch for The actions reported are generic rather than case-specific, so they do not reconcile to the corrective action tracker.

Before you start

  • Have you first decided which worker groups you will cover here, including any groups you have singled out for extra attention, and which engagement routes you will describe for them?
  • Before drafting, have you fixed whether any staff agreement is in place, and if so, what parts of the workforce it covers and where that coverage sits?
  • Have you chosen the channels people can use to raise concerns, and do you know whether you are reporting a formal complaint route or only other speaking-up routes?
  • For any case counts or closure rates, have you settled the time basis and source record you will use so the figures can be traced back?
  • Have you agreed what you mean by a case being raised, resolved, or fixed in practice, so the same definition is used throughout?
  • Have you identified the process used to put things right, and can you link the actions taken back to the cases they relate to?
+ Show S1-2 sub-elements (LRA working checklist)

How to prepare it

Set the reporting boundary first. Decide which parts of the business, workforce and value chain you will cover for this disclosure, then keep that boundary consistent across the rest of the response.
List the worker groups and participation routes you actually use. Identify the relevant groups, such as women, migrant workers and people with disabilities where applicable, and record the ways they can engage with the organisation.
Check whether formal worker agreements exist and define their reach. Note if there are any such arrangements, then state the scope they apply to and the coverage they provide in practice.
Map the complaint and issue-handling routes. Capture the channels people can use, whether a grievance route is in place, the cases raised through it, the share resolved, and your view on how well it works.
Describe how problems are put right. Set out the process used to remediate issues, note which cases were remediated, and summarise the actions taken to address them.
Document any exclusions, scope changes or judgement calls, then reconcile the draft against the official source. Make sure the final wording matches the underlying datapoints and that every required item is covered before sign-off.

Request the data

Request employee engagement and grievance records

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

How do we show the ways people can raise issues, how those issues are handled, and what follow-up or remedy has been put in place during the reporting period?

Use your organisation’s own terms first, then map them to the reporting disclosure. For example, if you call these routes, speak-up lines, case logs, employee forums, union consultations, or resolution actions, use those labels in the request and only translate them afterwards for reporting.

Weak request

Please provide the ESRS S1-2 engagement and grievance mechanism data, including stakeholder engagement methods, grievance channels, remediation, and effectiveness evidence.

Why it fails: It uses framework language that may not match how the business actually records the information, so the owner may not know which systems, teams, or case types to pull. It also does not specify the period, boundary, counting basis, or the exact internal records needed to support the figures and narrative.

Better request

Please send the people issue-handling and speak-up records for [reporting period] for [site/business unit]. We need the routes people use to raise concerns, any groups you tailor them for, any agreements that set out how they work, the channels available, whether a formal case route exists, the number of cases raised and resolved, how you assess whether the process works, and the remedy or follow-up actions taken. Please use your own team labels and include the source extract, date pulled, and any counting notes.

Formal email template
Subject: Request for people issue-handling and engagement records for [reporting period]

Hi [name/team],

We are preparing the sustainability reporting pack and need your help with the records that show how people can raise concerns, how those concerns are handled, and what follow-up actions were taken during [reporting period] for [entity / site / business unit].

Please share, in your team’s own terms first and with a short mapping note where helpful:
- the main routes people use to raise issues or ask for help
- any groups you specifically tailor these routes for, such as women, migrant workers, or people with disabilities, if applicable
- any agreements or arrangements that set out how these routes work, plus their scope and who they cover
- the channels available for raising concerns
- whether a formal case-handling route exists
- the number of cases raised in the period, the number resolved, and how you assess whether the process is working
- the process used to provide remedy or follow-up, the number of cases remediated, and the actions taken

Please include the source file or system extract, the date pulled, and any notes on definitions or counting rules. A possible LRA training template is attached for adaptation to your organisation. Please check the official source before sign-off.

Thanks,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name] — could you send the people issue-handling / speak-up records for [reporting period] for [site/business unit]? We need: the channels people use, any groups you tailor them for, any agreements and their scope/coverage, case counts, resolution rate, how you judge effectiveness, and the remedy/follow-up actions. Please use your team’s own labels and add a short mapping note. Include the source extract and date pulled. Thanks.

Industry examples

Manufacturing

Context. A multi-site employer with local worker forums, a hotline, and site-level case logs.

Adapted request. Please share the site forum notes, hotline summary, and case log extract for [reporting period] across [sites]. We need the routes workers use to raise issues, any groups you tailor them for, any site agreements, the channels available, whether a formal case route exists, case counts, resolution rate, effectiveness notes, and remedy actions.

Example response. Attached: hotline dashboard, site committee minutes, case log export. Labels used: worker forum, supervisor escalation, ethics line. Cases raised: 42; resolved: 39; remediated: 18. Notes include definitions, site coverage, and date pulled.

Retail

Context. A store-based workforce with a central employee relations team and a third-party speak-up provider.

Adapted request. Please send the store and head-office speak-up records for [reporting period]. We need the channels available to colleagues, any groups we specifically support, the case-handling route, the number of cases raised and closed, how you judge whether the process is effective, and the follow-up actions taken.

Example response. Attached: provider summary, ER tracker, policy note. Labels used: colleague helpline, manager escalation, HR case portal. Cases raised: 87; resolved: 81; remediated: 26. Coverage and counting rules are noted in the cover sheet.

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

Explain which groups were included in the engagement review, what counted as an engagement method, how agreements were identified, and how scope and coverage were defined for the reported arrangements.

Context note

Set out what the figures show about how the organisation engages with people, what channels are available for raising concerns, how many cases were received and resolved, and what remediation steps were taken where issues were found.

Fluctuation statement

If the numbers changed from one period to the next, link the movement to changes in engagement activity, channel use, case volumes, resolution performance, or the extent of remediation work carried out.

Content index entry

S1-2 Engagement & Grievance Mechanisms — [location / page] / [notes]

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Preparation tools & forms

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Check

For each claim, check the evidence

  • We based the coverage figure on the workforce population we could evidence for the reporting period, and we documented any exclusions, cut-off dates, and duplicate records removed before the number was finalised.

    Risk An assurer may test whether the reported coverage is complete, whether exclusions were applied consistently, and whether the figure could be overstated or understated by missing sites, entities, or worker groups.

    Evidence to check ['Workforce population extract used for the calculation', 'Rules for inclusions and exclusions, including period cut-off', 'Reconciliation showing removals of duplicates or inactive records', 'Sign-off or review note confirming the final figure']

  • For the narrative on how we understand views from more exposed or less visible worker groups, we relied on documented engagement records, meeting notes, survey outputs, and any targeted listening sessions, and we kept the source material that supports the summary we published.

    Risk An assurer may probe whether the statement is supported by real engagement rather than general intent, whether the groups described were actually reached, and whether the summary overstates the depth or breadth of insight obtained.

    Evidence to check ['Engagement logs and attendance records', 'Survey results or interview notes for the relevant worker groups', 'Internal summary showing how inputs were turned into the disclosure', 'Evidence of management review of the final wording']

  • Where we refer to agreements or outcomes with worker representatives, we checked the signed documents, mapped which parts of the workforce they cover, and recorded the business units, locations, or worker categories included before publishing the statement.

    Risk An assurer may test whether the agreement or outcome really exists, whether the stated coverage is accurate, and whether the disclosure implies wider reach than the underlying document supports.

    Evidence to check ['Signed agreement or formal outcome record', 'Coverage mapping by site, entity, function, or worker group', 'Legal or HR review confirming the scope description', 'Version-controlled draft showing how the final wording was approved']

  • When we said the concern channel review was judged against recognised good-practice features, we kept the assessment matrix, the scoring notes, and the evidence showing how each feature was tested before the report went out.

    Risk An assurer may challenge whether the assessment was actually performed, whether the criteria were applied consistently, and whether the channel was assessed on the basis claimed rather than by informal judgement.

    Evidence to check ['Assessment matrix or checklist used for the review', 'Supporting evidence for each scored feature', 'Reviewer notes explaining any judgement calls', 'Approval record for the published assessment']

  • Our description of workforce engagement was built from direct meetings, representative discussions, and documented feedback, and we retained the records showing how those views influenced the actions or decisions we reported for the year.

    Risk An assurer may probe whether the engagement was direct and current, whether representative views were fairly reflected, and whether the reported decisions can really be traced back to workforce input.

    Evidence to check ['Meeting minutes, consultation notes, or feedback summaries', 'Records from worker representatives where relevant', 'Traceability note linking input to decisions or actions', 'Management approval of the final disclosure']

  • Where we pointed readers to the policy covering retaliation protection for people using the channel, we checked that the cross-reference matched the current policy version and that the policy was in force at the reporting date.

    Risk An assurer may test whether the cross-reference is current, whether the linked policy actually covers anti-retaliation protections, and whether the disclosure points to the right document version.

    Evidence to check ['Current policy document and version history', 'Cross-reference check between the report and the policy', 'Approval or publication date showing the policy was active', 'Document control log']

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 the wrong team, so the data comes from people who do not run the staff channels, case handling, or follow-up actions in practice.
  • Framework language onlyThe data call uses disclosure terms instead of the organisation’s own labels, and the source team cannot map them cleanly to its internal records.
  • No scope setThe collector never defines which workforce groups, sites, or entities are in scope, so the figures mix together records that should have been kept separate.
  • Wrong period basisThe team pulls numbers from a different reporting window or cut-off date, so the dataset does not match the period being reported.
+ Show 5 more

Judgement needed

  • Acquisitions and disposals during the yearDecide whether to include only the people and channels in the business at the reporting date or to also reflect parts added or removed during the year, and explain the cut-off used.
  • Different local labels for the same worker groupsWhere countries use different labels or legal categories, map them to a single internal grouping approach and state the mapping rule so readers can see how like-for-like groups were combined.
  • People just outside the formal workforceSet out whether contractors, agency staff, interns, or other near-scope groups are counted in the engagement and complaint channels, and explain the boundary if they are partly included or excluded.
  • Which channels count as a complaint routeChoose whether to list only dedicated issue-reporting routes or also broader speaking-up, HR, union, or hotline channels, and describe the basis for that choice.
+ Show 6 more

Examples

How it reads on the page

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

Illustrative (synthetic) example — Food manufacturing

We used a mix of staff forums, one-to-one interviews, site walkabouts and worker-representative meetings to hear from people most likely to face barriers, including women, migrant workers and colleagues with disabilities. We had written arrangements with 3 of our 5 main labour suppliers, covering 420 of 500 workers in scope; our reporting channels were open to all staff and contractors, 18 concerns were logged, 15 were closed out, and we judged the process effective because most cases were handled within target times and users said the routes were easy to access.
- Where harm had already occurred, we used case-by-case fixes such as pay corrections, schedule changes, equipment adjustments and manager retraining; 11 matters were fully put right during the period.
- The figures above are internally consistent and illustrative only.

Synthetic, practitioner-facing example showing how a company might describe worker engagement, reporting routes, case handling and remedy in plain language.

Illustrative (synthetic) example — Logistics and warehousing

We gathered views through toolbox talks, shift huddles, anonymous surveys and meetings with elected worker representatives, with extra outreach to women, migrant colleagues and employees with disabilities. We had formal agreements with 2 of our 4 key service partners, covering 260 of 320 people in the relevant workforce; our speaking-up routes included phone, web and in-person options, 9 matters were raised, 8 were closed, and we assessed the system as working well because access was broad and most issues were settled without delay.
- When something needed fixing, we used tailored remedy steps such as reinstating hours, replacing damaged equipment, adjusting duties and giving refresher training; 6 cases were remedied in full.
- This is a made-up example for training and review.

Synthetic, practitioner-facing example showing a different sector and a different mix of engagement, reporting and remedy practices while keeping the figures internally consistent.

Quality ladder

  • Basic

    I have a worker feedback route and a complaint channel.

  • Better

    I use staff forums, direct manager check-ins and a confidential reporting line, and I have a complaint process that handled 18 cases this year, with 15 closed.

  • Best

    I use staff forums, manager check-ins and a confidential reporting line across our main workforce and contractor groups, and I have a complaint process that handled 18 cases this year, closed 15, and improved after we added a faster triage step because several cases were taking too long to review.

Check your understanding

Scenarios to work through

A preparer is drafting the people section and has one consultation log for the year, but it only covers office staff. The business also has migrant workers and employees with disabilities, and there were separate listening sessions for each group.

QHow should the team decide what to include about who was consulted and how the consultation was done?
Reveal model answer →

A grievance hotline exists for all staff, but the team is unsure whether to present it as a formal complaint route because some issues are also handled through line managers and HR. During the year, 18 cases were logged and 15 were closed.

QWhat should the preparer do when describing the complaint route and the cases raised through it?
Reveal model answer →

The company has a worker feedback process in place, but the team has not checked whether it actually works well. They know that 12 matters were closed during the year, while 3 remain open, and they have no documented review of whether users trust the process.

QHow should the team judge whether to say the process is effective?
Reveal model answer →

A worker complaint about unsafe conditions was resolved by changing the shift pattern and providing new protective equipment. Another complaint about pay was closed after a discussion, but no follow-up action was taken. The draft report currently says only that matters were “handled”.

QWhat should the preparer include about remedy and follow-up actions?
Reveal model answer →
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Framework references

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FAQ

Questions this page answers

How do I prepare disclosure S1-2 on own workforce engagement using this page?+
What data do I need to collect for S1-2 own workforce engagement?+
How should I define the scope and methodology for S1-2 own workforce engagement?+
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What evidence pack do I need for assurance on S1-2 own workforce engagement?+
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How do I use the Prep & Assurance workbook for S1-2 own workforce engagement?+
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Can I use the synthetic example disclosure on S1-2 own workforce engagement as a template?+
Where can I find real company report examples for S1-2 own workforce engagement?+

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