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London Reporting Academy ESRS S2 · Workers in the Value Chain · Disclosure Requirement S2-1

Applicable from FY2027

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

Policies (Value Chain Workers)

S2-1 · mandatory · coverage + narrative

This disclosure asks an organisation to explain the policies it has in place for workers in its value chain, and how those policies are used in practice. In plain terms, it is about showing whether the organisation has clear rules or commitments that cover the people who make, handle, transport, sell, or otherwise support its products and services outside its own workforce, and what those rules are meant to achieve.

Disclosure focus

The practical focus is on whether those policies are broad enough to apply across the relevant parts of the value chain, rather than only to a few visible or high-profile sites or suppliers. The organisation should make clear where the policies apply, who they cover, and whether they are embedded in day-to-day management of supplier and contractor relationships, not just stated at a high level.

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.

  • Forced labour flag

    Legal / Human Rights / Sustainability reporting

    Record whether the organisation has identified any forced labour risk or incident for the reporting period, using the same basis applied in internal monitoring and case tracking.

    Evidence Human rights due diligence findings, incident logs, audit or investigation records, and the period-end compliance status used by legal or sustainability reporting.

    Watch for The yes/no flag is set from a general risk view rather than the incident register, so the reported answer does not reconcile to case tracking for the period.

  • Child labour flag

    Legal / Human Rights / Sustainability reporting

    Record whether the organisation has identified any child labour risk or incident for the reporting period, based on the organisation’s own monitoring and case records.

    Evidence Audit findings, grievance or incident logs, remediation records, and the period-end status held by legal, compliance, or sustainability teams.

    Watch for The flag is taken from a policy review rather than the incident log, so the reported answer does not reconcile to the source system for the period.

  • Trafficking flag

    Legal / Human Rights / Sustainability reporting

    Record whether the organisation has identified any trafficking risk or incident for the reporting period, using the same internal source used to track allegations, investigations, and outcomes.

    Evidence Investigation files, hotline or grievance records, audit reports, and the period-end status maintained by legal, compliance, or sustainability reporting.

    Watch for The yes/no answer is based on a narrative assessment rather than the case register, so the reported flag does not reconcile to the underlying records.

  • Supplier code adoption

    Procurement / Legal / Sustainability reporting

    Record whether suppliers are expected to follow a formal supplier code or equivalent supplier-facing standard, as applied in procurement and supplier onboarding.

    Evidence Supplier code document, procurement policy, onboarding pack, contract templates, and supplier compliance records.

    Watch for The answer is marked yes for a draft or regional template, but the live supplier onboarding process does not actually include the code.

  • Supplier coverage rate

    Procurement / Supply chain / Sustainability reporting

    Capture the share of suppliers that are within the stated supplier code or equivalent standard, using the organisation’s defined supplier population and the same counting basis throughout.

    Evidence Supplier master data, procurement coverage analysis, contract repository, and the calculation file showing numerator, denominator, and period.

    Watch for The percentage mixes active suppliers with all vendors, so the denominator is not aligned to the supplier population used in procurement records.

  • Enforcement actions

    Procurement / Legal / Sustainability reporting

    Describe the actions used when suppliers do not follow the supplier code, such as review, escalation, remediation, suspension, or termination, in the way procurement actually applies them.

    Evidence Supplier code, escalation procedure, contract clauses, remediation logs, and records of supplier breaches and follow-up actions.

    Watch for The description is written from policy language, but the actual enforcement steps in procurement and contract management are different.

  • Policy title

    Legal / Sustainability / Policy owner

    Capture the exact name of the policy that sets the organisation’s approach to the topic, as it appears in the approved policy library.

    Evidence Approved policy register, document control system, board or management approval record, and the current published policy file.

    Watch for The title is copied from an old draft or local variant, so it does not match the current approved policy record.

  • Policy reach

    Legal / Sustainability / Policy owner

    State which parts of the organisation’s value chain the policy applies to, using the organisation’s own business description of where it operates and where the policy is intended to apply.

    Evidence Policy text, scope statement, supplier or customer standards, and internal guidance showing whether it applies before or after the organisation’s own operations.

    Watch for The scope is described as upstream when the policy only applies to downstream activities, so the direction of coverage is wrong.

  • Covered worker groups

    HR / Legal / Sustainability reporting

    List the worker groups the policy is meant to cover, using the organisation’s own categories for employees and any other people included in the policy.

    Evidence Policy text, HR or workforce definitions, contractor or agency worker guidance, and any implementation notes showing which groups are included.

    Watch for A worker group is omitted or misclassified, so the policy coverage does not match the organisation’s own workforce categories.

  • Geographic coverage

    Legal / Compliance / Sustainability reporting

    State the countries or regions where the policy applies, using the organisation’s own operating footprint and the locations named in the policy.

    Evidence Policy text, country list, regional operating map, and any implementation guidance that limits or extends the policy by location.

    Watch for The geography is taken from headquarters location rather than the actual operating countries, so the reported scope is too narrow.

Before you start

  • Have you fixed which policy name you will use, and is it the one that actually covers the worker groups and places you mean to report on?
  • Before you draft, have you decided whether the policy reaches only suppliers, only customers, or both sides of the chain?
  • Have you checked which worker groups and which countries or regions sit inside your chosen scope, so you do not mix covered and uncovered areas?
  • For the three harm topics, have you settled whether your policy clearly addresses forced labour, child labour, and trafficking, or only some of them?
  • If you plan to state supplier coverage, do you have a traceable source for the percentage and a clear basis for how that figure was calculated?
  • Have you agreed what practical controls back the policy in day-to-day use, and can you point to the source that supports that description?
+ Show S2-1 sub-elements (LRA working checklist)

How to prepare it

Start by pinning down the policy you are reporting on: record its name, then state whether it applies to activities before your own operations, after them, or both. Add the worker groups it reaches and the countries or regions it covers, so the reporting boundary is clear from the outset.
Decide what counts as covered for the three labour-risk topics. Use a consistent internal definition for each one, and make sure the team applying the disclosure understands which cases are treated as forced labour, child labour, or trafficking for this report.
Gather the source material that supports the yes/no answers and the descriptive fields. Pull together the policy document, any supplier standards, and any records that show how the policy is applied across the relevant parts of the value chain and workforce groups.
Complete the disclosure by entering the three boolean answers and the related narrative or figures. For the supplier standard, state whether one exists, give the share of suppliers it reaches, and describe the ways it is enforced.
Explain any gaps, exceptions, or changes in approach. If a field is not fully covered in the period, or if the scope has shifted, note that clearly so readers can understand what the numbers and statements do and do not include.
Check the draft against the source records and the official ESRS wording before sign-off. Confirm that the policy name, scope, worker groups, geography, labour-risk topics, supplier standard coverage, and enforcement details all match the underlying evidence.

Request the data

Request the supplier policy evidence pack

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

What policy and control evidence do we have for labour-rights expectations across our supplier and other value-chain worker relationships?

Use your organisation’s own terms first, then map them to the reporting categories. For example, if you talk about supplier standards, vendor rules, contractor requirements or partner conduct, use those labels in the request and only translate them afterwards for reporting. Keep the ask in the language the owner already uses internally, and check the official source before sign-off.

Weak request

Please provide the ESRS S2-1 policy disclosures for value chain workers, including the policy, coverage, scope, and enforcement mechanisms.

Why it fails: It uses reporting-framework language that many operational owners will not use day to day, so the recipient has to translate the ask before they can answer. It also does not tell them which internal documents, systems, or business labels to pull from, which makes the request slower and more likely to come back incomplete.

Better request

Please send the current supplier and third-party labour policy pack for [period], including the policy name/version, the supplier groups and worker groups it covers, the countries or regions in scope, the share of suppliers covered, and the controls used to apply it. Use your own internal labels first, then we will map them for reporting.

Formal email template
Subject: Request for supplier policy evidence for [reporting period]\n\nHi [name],\n\nWe are preparing the sustainability reporting pack and need your help with the evidence for our supplier and other third-party labour expectations. Please send the current policy or standard, plus the supporting details below, for [reporting period] and the in-scope business areas.\n\nPlease include:\n- the policy or standard name and version\n- the parts of the business and supplier types it covers\n- the worker groups it applies to\n- the countries or regions covered\n- whether it applies to upstream, downstream, or both parts of the value chain\n- the share of suppliers covered, and how that share was calculated\n- the controls used to apply it in practice, such as contract wording, onboarding checks, audits, follow-up actions, or escalation steps\n- the source file or system link\n- the owner, approver, and approval date\n\nIf you use different internal labels, please keep your own wording and add a short note so we can map it later. Please send this in a table or short pack by [date].\n\nThanks,\n[preparer name]
Short Teams / Slack version
Hi [name] — could you send the current supplier / third-party worker policy pack for [period]? Please include the policy name/version, who it covers, where it applies, the share of suppliers covered, and how it is enforced in practice. Use your team’s own terms; we’ll map them later. Thanks — [name]

Industry examples

Manufacturing

Context. The business buys components from direct suppliers and uses logistics contractors and labour agencies at some sites.

Adapted request. Please send the current supplier standards pack for [period], including the code or supplier rules, the supplier and contractor groups it covers, the sites and countries in scope, the share of active suppliers covered, and the checks used to apply it in practice.

Example response. Policy: Supplier Standards v3.1; Scope: direct material suppliers, logistics contractors and labour agencies; Coverage: 87% of active suppliers by count and 92% of annual spend; Enforcement: contract clauses, onboarding review, annual audits and corrective-action follow-up; Source: procurement policy library.

Retail / Wholesale

Context. The business sources finished goods from overseas suppliers and uses fulfilment partners and franchise-style arrangements in some markets.

Adapted request. Please share the current supplier conduct pack for [period], including the policy name/version, the supplier and partner groups it applies to, the countries covered, the share of suppliers covered, and how breaches are handled.

Example response. Policy: Responsible Sourcing Code v5.0; Scope: merchandise suppliers, fulfilment partners and selected franchise partners; Coverage: 74% of active suppliers and 81% of purchase value; Enforcement: supplier onboarding, contract terms, periodic reviews, escalation to remediation, and suspension for unresolved issues; Source: supplier portal and contract repository.

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 how the organisation defined the policy scope, the worker groups included, the geographic boundaries used, and how supplier coverage and enforcement were assessed from the underlying records.

Context note

Set out what the figures show about how far the policy reaches across the business, which supplier groups are covered, and whether the controls are designed to address forced labour, child labour, and trafficking risks.

Fluctuation statement

If coverage or enforcement changed from the prior period, note whether this was driven by a revised policy scope, a wider supplier population, or a change in how the organisation applies its controls.

Content index entry

S2-1 Policies (Value Chain Workers) — [location / page] / [notes]

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Preparation tools & forms

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Check

For each claim, check the evidence

  • I checked that the policy note names the relevant policy or policies we use to manage the material issues for workers in the value chain, rather than relying on a generic statement.

    Risk An assurer may question whether the disclosure is specific enough to show which policy documents actually exist and whether they are the ones used for the reported topic.

    Evidence to check Approved policy documents, policy register or inventory, cross-reference to the report draft, and sign-off showing the named policies match the current internal documents.

  • I confirmed that the write-up says whether we have a broad human rights policy and, if so, that it is framed as a commitment to apply the three named international frameworks.

    Risk The assurer may probe whether the company has overstated the existence or scope of a group-wide human rights commitment, or whether the statement is supported by the underlying policy text.

    Evidence to check The policy text, board or management approval records, legal or sustainability review notes, and a mapping showing where the three frameworks are reflected in the policy.

  • I verified that the coverage statement explains which parts of the business and value chain are in scope, and where we have left things out, including the relevant locations and worker groups.

    Risk The assurer may challenge whether the stated scope is complete, internally consistent, and aligned to the actual boundaries used in the underlying assessment.

    Evidence to check Scope memo, boundary-setting paper, organisational and value-chain maps, list of included and excluded sites or activities, and the working papers used to prepare the disclosure.

  • I checked that the policy section explains how we took account of the interests of affected people when setting the rules for value-chain workers.

    Risk The assurer may ask whether this is a genuine description of how stakeholder views informed the policy, or just a generic assertion with no traceable basis.

    Evidence to check Stakeholder engagement records, consultation summaries, meeting notes, grievance or feedback logs, and evidence showing how those inputs influenced policy wording or revisions.

  • I confirmed that the disclosure states whether our worker-related policies cover trafficking, forced labour and child labour, and that the wording matches the actual policy content.

    Risk The assurer may test whether the report overstates coverage by implying these topics are addressed when the policy only mentions them indirectly or partially.

    Evidence to check Relevant policy clauses, supplier standards or code provisions, legal review notes, and a topic-to-policy mapping showing where each issue is addressed.

  • I checked that the supplier code section says whether such a code exists, and that any coverage figure is calculated from the same supplier population used in the supporting analysis.

    Risk The assurer may probe whether the existence claim is supported and whether the percentage is based on a clearly defined denominator with no double counting or omitted suppliers.

    Evidence to check Supplier master data, the code distribution or acceptance log, calculation workbook, definition of the supplier population, and reconciliation to procurement records.

Evidence pack to prepare

Common reporting gaps

  • A percentage is stated without the underlying counts (numerator and denominator).
  • The denominator — what the figure is a share of — is not explained.
  • Partial scope is reported as if it were complete coverage.
  • One-off activities are counted as if they were ongoing programmes.
  • Boundary or period changes that move the figure are not flagged.
  • Exclusions from the reported scope are not listed or explained.

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 ownerChasing the policy team alone can miss the people who actually run supplier controls, so the answer comes from the wrong desk.
  • Framework language onlyAsking for the data in ESRS-style terms can confuse colleagues, because they know the process by their own internal policy names and control labels.
  • Scope left vagueIf you do not pin down which parts of the supply chain are in scope, teams may mix upstream and downstream coverage or leave out a whole segment.
  • Wrong worker group splitCombining different groups of external workers into one bucket can hide which group is covered by which policy and blur the result.
+ Show 4 more

Judgement needed

  • Defining the policy boundary after a deal closesIf a business is bought, sold or restructured during the year, decide whether the policy description and coverage figures follow the opening set-up, the closing set-up, or a weighted view, and explain the cut-off used.
  • Reconciling local labour-law labels to one group policyWhere country-level terms for prohibited work or protected worker groups do not line up neatly, map them to a single internal wording and state how the local differences were handled.
  • Including workers near the edge of the supply chainFor contractors, agency staff, seasonal labour, home-based workers or other borderline groups, set out whether they are treated as in scope and why that call was made.
  • Choosing which parts of the chain the policy coversIf the policy applies only to selected buying, production or sales activities, describe the business areas included and excluded, and make clear whether the scope is upstream, downstream or both.
+ Show 4 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 — Apparel manufacturing

We have a group-wide human-rights policy for our upstream supply chain, covering factory workers, home-based workers, migrant labour, and temporary agency staff across our sourcing countries in Asia, Europe, and North Africa. We also require a supplier code for 92% of direct suppliers by count, and we use audits, corrective-action follow-up, and contract remedies where breaches are found.
- In our latest review, we did not identify any confirmed cases of forced labour, child labour, or trafficking in the covered scope.

This is a synthetic, illustrative narrative showing how a reporter might describe a policy, its reach, supplier-code coverage, enforcement approach, and a zero-incident outcome for the three labour-abuse indicators.

Illustrative (synthetic) example — Food processing

Our group applies a labour-rights policy across both our own operations and selected downstream distribution partners, with the main focus on warehouse staff, transport workers, seasonal workers, and agency labour in the UK, Ireland, and Spain. A supplier code is in place for 78% of relevant suppliers, and we back it with training, site visits, escalation to senior management, and suspension of business where needed.
- We recorded no confirmed instances of forced labour, child labour, or trafficking in the reporting period.

This is a synthetic, illustrative narrative showing a second plausible reporter with a different sector, broader scope, partial supplier-code coverage, a different enforcement mix, and a zero-incident outcome for the three labour-abuse indicators.

Quality ladder

  • Basic

    We have a supplier labour policy.

  • Better

    We apply our supplier labour policy to upstream and downstream partners, covering direct and indirect workers across all regions, and 82% of suppliers are in scope.

  • Best

    We use our supplier labour policy across upstream and downstream partners for direct and indirect workers in all regions, covering 82% of suppliers this year, and the share rose because we added more tier-two suppliers after a wider contract review.

Check your understanding

Scenarios to work through

A preparer is drafting the policy note for a group that buys components from Asia and sells finished goods through distributors in Europe. The draft policy covers labour risks in the supply base, but it does not yet say which worker groups are in scope or which countries are covered.

QShould the note stay at that high level, or should it also spell out the policy name, whether it applies upstream, downstream, or both, which worker groups it covers, and the geographic reach?
Reveal model answer →

A company has a supplier standard that bans forced labour, child labour, and trafficking in its direct sourcing network. The same document also says suppliers must pass the rule on to subcontractors, but the preparer is unsure whether to report the policy as covering only direct suppliers or the wider chain.

QHow should the scope be described when the policy reaches beyond first-tier suppliers through contractual flow-down?
Reveal model answer →

The legal team confirms the group has a supplier code, and procurement says 82% of suppliers by spend have accepted it. However, there is no clear process for what happens when a supplier breaches the code beyond a general statement that issues are reviewed case by case.

QIs naming the code and giving the coverage percentage enough, or does the disclosure also need to explain how the code is put into practice when breaches occur?
Reveal model answer →

A preparer has three separate internal documents: one on labour standards, one on supplier conduct, and one on human rights due diligence. The team is unsure whether to present them as one combined policy or as separate items, and whether to mention that the labour standard is the main document used for value chain workers.

QHow should the policy name be handled if several documents together shape the approach to workers in the chain?
Reveal model answer →
✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

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Framework references

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S2-1

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FAQ

Questions this page answers

How do I use the S2-1 page to prepare a disclosure on workers in the value chain without treating it as an official standard?+
What datapoints do I need to collect for S2-1 on workers in the value chain?+
How should I set the scope for S2-1 workers in the value chain?+
Who should own the S2-1 data collection and sign-off process?+
What evidence pack do I need to make an S2-1 disclosure assurance-ready?+
What are the six assurance claims on the S2-1 page and how do I use them?+
What are the common reporting gaps or mistakes for S2-1 workers in the value chain?+
How do I use the Prep & Assurance workbook for S2-1?+
What is the printable Library Card for S2-1 and when should I use it?+
How do I turn the S2-1 page into a draft disclosure?+

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