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.
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Forced labour flag
Legal / Human Rights / Sustainability reportingRecord 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.
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Child labour flag
Legal / Human Rights / Sustainability reportingRecord 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.
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Trafficking flag
Legal / Human Rights / Sustainability reportingRecord 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.
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Supplier code adoption
Procurement / Legal / Sustainability reportingRecord 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.
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Supplier coverage rate
Procurement / Supply chain / Sustainability reportingCapture 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.
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Enforcement actions
Procurement / Legal / Sustainability reportingDescribe 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.
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Policy title
Legal / Sustainability / Policy ownerCapture 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.
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Policy reach
Legal / Sustainability / Policy ownerState 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.
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Covered worker groups
HR / Legal / Sustainability reportingList 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.
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Geographic coverage
Legal / Compliance / Sustainability reportingState 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?
How to prepare it
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]Download Centre
Preparation tools & forms
Download preparation tools for S2-1 with free verified email access for 24 hours. Source-report links remain public.
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.
- Wrong timing basisUsing a different cut-off date or reporting period from the one used in the source records can make the collected data inconsistent with the underlying evidence.
- Mixed counting basisIf one source counts suppliers by legal entity and another by site or contract, the coverage figure will not match the same population throughout.
- Source labels lostCopying figures without the original file names, system tags, or document titles makes it hard to trace where each value came from.
- Evidence trail missingWhen the team keeps the numbers but not the supporting notes, approvals, and version history, no one can show how the data was checked before sign-off.
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.
- Using a snapshot date or an average viewWhen the covered population changes through the year, pick one basis for the coverage percentage and say whether it reflects a point-in-time count, a period average, or another consistent method.
- Mixing direct records with estimatesIf complete headcounts or supplier counts are not available, use a clear estimate method, identify which figures are measured and which are approximated, and explain the main assumptions.
- Rounding the coverage percentageAgree a rounding rule for the supplier coverage figure, apply it consistently, and note it if the published percentage differs slightly from the underlying calculation.
- Aggregating sensitive workforce informationWhere naming a worker group, country or supplier could expose personal data or create confidentiality issues, combine the information at a higher level and explain the aggregation approach.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
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.
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.
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.
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.
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.
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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
S2-1
within ESRS S2: Workers in the Value Chain
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Use the page as practitioner guidance only: start with the plain-language explainer, then work through the datapoints to prepare, the step-by-step preparation section, and the draft-output section. It is designed to help you assemble a draft and evidence pack, not to replace your organisation’s own reporting judgement or review process.
The page lists the datapoints to prepare: forced labour flag, child labour flag, trafficking flag, supplier code adoption, supplier coverage rate, enforcement actions, policy title, policy reach, covered worker groups, and geographic coverage. Use that list to define your data request and check that each item has an owner and source.
The page points you to policy reach, covered worker groups, and geographic coverage as the main scope-setting datapoints. In practice, use those fields to make clear which workers, suppliers, and locations are included in the draft disclosure.
The page is built for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can confirm the underlying data and evidence. Use the workbook and evidence pack to assign each datapoint to a named owner before drafting.
The page includes an evidence pack with five items for assurance readiness, alongside six assurance claims to verify. Use those materials to build a file that links each reported point back to source evidence and a clear reviewer trail.
The page says there are six assurance claims to verify, each framed around claim, risk, and evidence. Use them as a checklist to test whether the draft disclosure is supported by the underlying records before it goes to review.
The page includes a list of common reporting gaps and mistakes to help you avoid weak or incomplete drafting. Use that section as a pre-submission check, especially where a datapoint is missing, unclear, or not backed by evidence.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track ownership, and assemble the evidence needed for a draft and assurance review.
The Download Centre also includes a printable Library Card in .pdf format. Use it as a quick reference while you are preparing the disclosure, checking the evidence pack, or reviewing the draft output.
The page has a draft-output section with visualisation ideas, narrative starters, and a content-index line. Use those prompts to turn your collected data into a short narrative and a structured draft that matches your internal reporting format.
More questions this page can help with