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 engagementDescribe 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 engagementList 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 engagementSet 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 engagementState 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 engagementIf 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 engagementExplain 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 / HRDescribe 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 / HRState 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 / HRCapture 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 / HRReport 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 / HRExplain 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 / legalDescribe 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 / legalCapture 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 / legalList 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?
How to prepare it
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]Download Centre
Preparation tools & forms
Download preparation tools for S1-2 with free verified email access for 24 hours. Source-report links remain public.
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.
- Mixed counting basisSome fields are counted by people, others by cases or actions, but the source files do not state the basis used, so the totals cannot be compared reliably.
- Source labels lostOriginal system names, case IDs, or channel tags are stripped out during collection, making it impossible to trace each figure back to the underlying record.
- Populations mergedRecords for different groups, such as women, migrant workers, or people with disabilities, are combined into one pool even though they should be tracked separately.
- Missing evidence trailThe pack is saved without the supporting file names, dates, or approver trail, so no one can show where the data came from or who checked it.
- No sign-off recordThe final dataset is used before the owner has confirmed it, leaving no clear trail that the numbers were reviewed and accepted before drafting.
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.
- Agreements with worker representativesIf there are arrangements with employee representatives, clarify which parts of the workforce they cover and whether coverage is full, partial, or limited to certain sites or countries.
- Counting cases and measuring resolutionState whether case numbers and closure rates are based on opened cases, closed cases, or another internal measure, and keep the same basis across the period or explain any change.
- Effectiveness judged by numbers or by reviewExplain whether the assessment of how well the channels work is based on operational metrics, management review, user feedback, or a mix of these, and disclose the method used.
- Privacy-driven grouping of sensitive dataWhere small numbers could identify individuals, combine categories or locations before reporting and say that the figures were aggregated to protect privacy.
- Estimated figures versus system extractsIf some data come from manual estimates rather than a system report, identify the estimated items, the source used, and any known limits on accuracy.
- Rounding and presentation of percentagesApply one rounding rule consistently to counts and percentages, and note it if rounding means subtotals do not add exactly to the total.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
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.
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.
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.
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.
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”.
Ask the Knowledge Hub AI Assistant about this disclosure
Get practical answers for your reporting context.
Check your text
Paste one or two paragraphs. The fragment is used for this check only and is not stored in your conversation.
Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
S1-2
within ESRS S1: Own Workforce
Guides that settle this question
Related & explore
More in ESRS S1 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
Use the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page is designed to help you turn those inputs into a draft disclosure, not to replace your own judgement or internal process.
The page lists the core datapoints to gather, including engagement approach, priority groups, methods, agreements, reporting channels, grievance route, issues raised, closure rate, channel effectiveness, remedy process, remedied cases and remedial actions. Treat that list as the starting point for your data request and evidence check.
The page gives a step-by-step preparation section and a set of datapoints that help you frame scope and method, such as who was engaged, how they were engaged, and what channels or grievance routes were used. It does not set a formal methodology, so you need to align the page to your organisation’s own approach.
The page is aimed at sustainability and ESG managers, HR teams, data owners and assurance reviewers, so ownership usually needs to sit with whoever can coordinate those inputs and evidence. Use the page to split responsibilities across content, data, and assurance readiness rather than leaving it with one person alone.
The page includes an evidence pack with five items for assurance readiness, plus six assurance claims to verify with claim, risk and evidence. Use those materials to build a traceable pack that supports the numbers and narrative you plan to disclose.
The page has a section on common reporting gaps and mistakes, which is useful for checking whether your draft is complete and internally consistent. Use it as a final review step before sign-off and assurance.
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise preparation and assurance work. Use it alongside the page’s datapoints, evidence pack and assurance claims to build a working draft.
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. That gives you a practical way to convert your collected data into a first draft and structure the supporting narrative.
Yes, but only as an illustrative starting point. The example is explicitly synthetic, so you should adapt it to your own data and make sure any quantitative table remains internally consistent.
The page includes a 'From company reports' table that links to real published reports where the topic is disclosed. Use it to see how others present similar information, but do not treat it as a substitute for your own disclosure approach.
More questions this page can help with