Disclosure focus
The practical focus is on coverage and accessibility, not just on describing a policy or a few flagship examples. An organisation should be clear about which parts of its operations and value chain are covered, whether the mechanisms are available in the places and contexts where workers are actually located, and how it knows the process is functioning in reality rather than only on paper.
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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Engagement routes
Sustainability / stakeholder engagementList the ways people can raise views or concerns with the organisation, and note which groups each route is meant to reach.
Evidence Stakeholder engagement plan, consultation logs, channel inventory, website or hotline records.
Watch for Channel list does not reconcile to the actual contact routes in use, so a live route is omitted or duplicated.
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Stakeholder groups
Sustainability / stakeholder engagementIdentify the groups the organisation has chosen to engage with for this topic, using the organisation’s own grouping logic.
Evidence Stakeholder map, materiality or engagement register, consultation plan, board or management papers.
Watch for Group names are mixed with a different taxonomy, so a key sub-population is left out or counted twice.
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Engagement approach
Sustainability / stakeholder engagementDescribe the methods used to engage those groups, such as meetings, surveys, forums or other direct contact methods.
Evidence Engagement logs, meeting notes, survey records, consultation summaries, facilitator reports.
Watch for Method descriptions do not match the underlying engagement records, so informal contact is reported as formal consultation.
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Agreed terms
Legal / sustainability / stakeholder engagementState whether there are agreed arrangements with the relevant groups for how engagement is carried out.
Evidence Signed agreements, memoranda, community protocols, supplier codes, meeting minutes.
Watch for The yes/no flag is set without checking the signed arrangement status, so an informal understanding is treated as an agreement.
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Agreement coverage
Legal / sustainability / stakeholder engagementIf such arrangements exist, describe which groups or relationships they cover and the practical scope of those arrangements.
Evidence Agreement schedules, annexes, stakeholder lists, contract or protocol references.
Watch for Scope is described at the wrong level, so the coverage of the arrangement is broader or narrower than the signed documents.
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Grievance routes
HR / legal / ethics / complianceSet out the ways people can raise complaints or concerns, including the channels available to them.
Evidence Grievance procedure, hotline details, web forms, posters, employee handbook, supplier portal.
Watch for Available routes do not reconcile to the live grievance system, so an active channel is missing from the disclosure.
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Formal process
HR / legal / ethics / complianceConfirm whether there is a formal process for handling complaints or concerns.
Evidence Policy approval, procedure document, case management workflow, governance sign-off.
Watch for The yes/no answer is based on a draft or local practice, not the approved process, so a non-formal route is treated as formal.
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Access conditions
HR / legal / ethics / complianceExplain how easy it is for people to use the complaint routes, including any language, location, cost, timing or other practical barriers.
Evidence Accessibility review, hotline scripts, translation records, user testing, policy notes.
Watch for Accessibility is described for the main office only, so remote, low-literacy or non-local-language users are missed.
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Complaint metrics
HR / legal / ethics / complianceReport the measures used to track how the complaint process is performing, such as volumes, ageing, outcomes or other chosen indicators.
Evidence Case management reports, dashboard extracts, KPI definitions, management packs.
Watch for KPI definitions are not aligned to the case system, so closed cases and open cases are mixed in the same measure.
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Resolved share
HR / legal / ethics / complianceShow the proportion of complaints or cases that were brought to a close through the process, using the organisation’s chosen calculation basis.
Evidence Case closure report, KPI workbook, complaints register, dashboard calculation notes.
Watch for Resolution rate is calculated on received cases instead of closed cases, so the numerator and denominator are mismatched.
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Reply timing
HR / legal / ethics / complianceReport how long it takes to respond to complaints or concerns, including the timing basis used for the measure.
Evidence Case timestamps, service-level reports, workflow logs, KPI definitions.
Watch for Response time uses calendar days in one source and working days in another, so the period basis is inconsistent.
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Fix-up process
HR / legal / ethics / complianceDescribe the process used to put things right after a complaint or concern is upheld or otherwise needs action.
Evidence Remediation procedure, case workflow, corrective action tracker, policy documents.
Watch for The process description does not match the actual case workflow, so follow-up actions are omitted or described at the wrong stage.
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Closed remedies
HR / legal / ethics / complianceReport the cases that were actually put right during the period, using the organisation’s closure and remedy definitions.
Evidence Case closure report, remediation tracker, complaints register, management dashboard.
Watch for Remediated cases are counted from the wrong period or closure status, so open cases are included or resolved cases are missed.
Before you start
- Have you already fixed which worker groups and other affected people you will cover, and which contact routes or dialogue methods sit inside that scope?
- For any joint arrangements with worker representatives or similar bodies, have you decided whether they exist and, if so, what part of the business they cover?
- Have you chosen the exact complaint routes to describe, and do you know whether there is one joined-up process or several separate ones?
- Can you trace the figures you plan to use for how the process works — such as how many cases are handled, how many are closed, and how quickly replies go out — back to a source record?
- Have you settled the time basis for the numbers and performance measures, so the period and cut-off are consistent across the data you will report?
- Do you have a clear internal definition for what counts as a resolved case and what counts as remedial action, so the same rule is used throughout?
How to prepare it
Request the data
Request supplier engagement and issue-handling evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How do we show which supplier groups we engage, what channels they can use to raise issues, and how those issues are tracked, resolved and remediated?
Use your team’s own terms first, then map them to the reporting fields. For example, if you talk about supplier forums, hotline cases, site visits, escalation logs or corrective actions, keep those labels in the request and only translate them afterwards for the disclosure pack. This is a training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the ESRS S2-2 engagement and grievance mechanism data for the period, including stakeholder groups, channels, accessibility, KPIs, response times, resolution rates, remediation processes and remediated cases.
Why it fails: It uses framework language that many operational teams do not use day to day, so the owner may not know which records to pull. It also bundles several ideas together without pointing to the team’s actual trackers, logs or process names, which makes the request harder to action and harder to evidence.
Better request
Please send the supplier engagement and issue-handling records for [reporting period] covering [business boundary]. I need the groups you work with, the ways they can raise concerns, whether there is a formal route and what it covers, the channels available, how accessible they are, the KPIs you already track, how you calculate response time and closure rate, and any remediation notes for cases closed in the period. Please use your own tracker or case log names and attach the source file or link.
Formal email template
Subject: Request for supplier engagement and issue-handling evidence for [reporting period] Hi [name/team], I’m pulling together the disclosure pack for [reporting period] and need your help with the supplier engagement and issue-handling information for [business boundary]. Please send the following in your own team’s language, with any supporting files or links: - the supplier groups you actively engage with; - the ways you engage them; - whether there is a formal route for raising concerns, and what it covers; - the channels available for raising issues; - how accessible those channels are; - the measures you already track for this process; - how you calculate response time and closure rate; - the process used to fix issues and any examples of cases closed during the period. If you have a dashboard, tracker, policy, procedure note, or case log, that would be ideal. Please include the period covered, the system or file name, and who owns the record. This is a training template only; please adapt it to your organisation and check the source material before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — I’m pulling the [reporting period] pack and need your supplier engagement / issue-log evidence for [business boundary]. Please share the groups you work with, the channels they can use, whether there’s a formal route, the KPIs you track, how you measure response/closure, and any remediation examples. A tracker, policy, dashboard or case log is fine. Please use your team’s own terms and include the source file/system. Training template only — adapt to your organisation and check the source material before sign-off.
Industry examples
Manufacturing
Context. A plant uses supplier audits, site meetings and a shared corrective-action tracker for logistics and component suppliers.
Adapted request. Please share the supplier forum notes, audit follow-up tracker and complaints log for [reporting period]. I need the supplier groups covered, the engagement routes used, the issue-reporting channels, whether the plant has a formal escalation route, the accessibility notes, the KPIs tracked, the response and closure measures, and the cases remediated during the period.
Example response. Attached: supplier engagement tracker, complaints register export, and corrective-action log. Supplier groups: tier 1 components, packaging, and transport providers. Channels: site visits, portal form, dedicated inbox. Formal route: yes, covers commercial and conduct issues. KPIs: average first response days, closure rate. Remediated cases: 12 closed, 9 with corrective actions completed.
Retail / Food Service
Context. A retailer manages supplier concerns through a vendor portal, buyer meetings and a central case-management inbox.
Adapted request. Please provide the vendor portal report and the supplier concern log for [reporting period]. Include the supplier groups you engage, the channels they can use, whether there is a formal concern route, how accessible it is, the measures you track, how you calculate response time and closure rate, and any remediation completed for closed cases.
Example response. Attached: portal report, concern log, and closure summary. Supplier groups: fresh produce, own-brand manufacturers, logistics partners. Channels: portal, email inbox, buyer meetings. Formal route: yes, covers payment, quality and conduct concerns. Accessibility: available in English and local-language support for key suppliers. Remediated cases: 7 closed, 5 with supplier action plans completed.
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 identified the affected groups, what it counts as an engagement route or complaint channel, and how it measured coverage, accessibility, performance and case handling.
Context note
Set out what the figures show about how people can raise issues, how the organisation responds, whether arrangements are formalised, and how many matters are resolved through remediation.
Fluctuation statement
If the figures moved materially, note whether the change came from adding or removing channels, changes in who was covered, shifts in accessibility, or differences in how many cases were received and resolved.
Content index entry
S2-2 Engagement & Grievance Mechanisms — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S2-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We used a documented method to decide which parts of the disclosed operations were included, and we can show why any exclusions were made.
Risk The coverage figure may be overstated, selectively framed, or based on an inconsistent boundary.
Evidence to check ['Boundary-setting memo or methodology note', 'List of included and excluded entities, sites, functions, or worker groups', 'Approval record for any exclusions or scope changes']
We based the disclosure on current-year information, with the underlying records traced back to named sources rather than unsupported estimates.
Risk The reported information may be incomplete, outdated, or not traceable to source records.
Evidence to check ['Source data extracts and system reports', 'Data lineage or traceability file', 'Version-controlled working papers showing the reporting period used']
Where we relied on judgement, we recorded the assumptions and applied them consistently across the figure and related narrative.
Risk Judgement may have been applied inconsistently or without a clear audit trail.
Evidence to check ['Assumption log', 'Calculation workbook with formula checks', 'Internal review notes showing consistent application']
Before publication, we carried out checks to spot missing items, duplicates, and obvious inconsistencies in the evidence pack.
Risk Basic data-quality issues may remain undetected, weakening the reliability of the disclosure.
Evidence to check ['Data validation checklist', 'Exception report and follow-up actions', 'Sign-off from the preparer and reviewer']
We kept supporting evidence for the channels, engagement activity, remedy arrangements, and any effectiveness review so an assurer can test what we said.
Risk The narrative may not be supportable because the underlying evidence is thin, fragmented, or not retained.
Evidence to check ['Meeting notes, logs, or correspondence', 'Copies of channel descriptions, process maps, or policy documents', 'Evidence retention index linking each statement to source material']
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 team asks the wrong business owner for the channel list or case data, so the figures come from someone who does not run the worker contact route or the case-handling process.
- Framework language onlyThe request is sent in ESRS-style terms instead of the organisation’s own labels, and the recipient cannot map the ask to the hotline, case log, or local escalation route they actually manage.
- Scope left vagueNo one fixes which worker groups, sites, or operating units are in scope, so the data pull mixes covered and non-covered populations.
- Wrong time basisThe team pulls records using a different cut-off or reporting window from the one used for the rest of the report, which makes the channel and case data inconsistent.
- Mixed counting basisOne extract counts unique people while another counts contacts or cases, so the numbers cannot be compared or rolled up cleanly.
- Source labels lostThe original system tags, case IDs, or channel names are stripped out during export, so the team cannot trace each figure back to the underlying record.
- Populations mergedSeparate worker groups that should stay distinct are combined into one file, which hides differences in how engagement or complaints are handled.
- Missing evidence trailThe file is saved without the supporting notes, extract date, or reviewer sign-off, so nobody can show how the number was built or approved.
Judgement needed
- Which worker groups sit inside the reporting boundary after a buy-in or saleUse the reporting period boundary you have set for the rest of the report, explain any added or removed sites or workforces, and state whether the engagement and complaint data include the changed population for the full year or only from the date of transfer.
- How to handle local labels that do not map neatly across countriesGroup similar worker categories under one plain description where local job titles differ, but explain the mapping you used so readers can see which people were counted together and where local practice led to a different split.
- Whether to include people just outside the formal workforce but still affectedDecide and disclose whether you have included contractors, agency staff, seasonal workers or other near-boundary groups in the channels and case counts, and make clear the rule used to include or exclude them.
- What counts as a channel versus a full complaint routeSeparate simple ways to raise a concern from a structured case-handling route, and explain if a hotline, manager route, union route or digital form is treated as one channel or several in your figures.
- How to describe access where language, literacy or disability support differs by locationState the practical access features in each operating area, and if support varies by country or site, explain the main differences rather than forcing a single global description that hides local limits.
- Which performance measures are based on actual case records and which are estimatedUse recorded case data where available, but if you need estimates for timing, closure or response measures, say so clearly and explain the method and any material assumptions behind the estimate.
- How to set the time cut-off for response and closure measuresChoose one consistent cut-off date and one timing basis for all locations, then explain whether you measure from receipt, acknowledgement or first action, and whether late-open cases are left open or carried into the next period.
- How to present very small numbers without exposing individualsRound or combine small counts where needed to protect privacy, but disclose the rule you used and make sure the published totals still reconcile to the underlying case population.
- How to report outcomes when a case is partly resolvedDefine whether a matter is counted as resolved only when every action is finished or when the main issue is closed, and explain how you treat cases with follow-up actions, partial fixes or ongoing monitoring.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We used several routes to hear from workers in our own operations and from people in the supply chain who may be affected, and we set out which groups were reached and how each route worked. Where we had formal arrangements with worker representatives, we noted that they covered our direct workforce and key contractor sites; we also kept a separate complaints route open to all relevant people, with access through site noticeboards, a phone line, email, and a web form, plus language support and options for shift workers and people with limited digital access.
- The complaints route was available across all sites, could be used without charge, and was designed to be reachable by workers, contractors, and other affected people; we tracked the number of matters raised, the share resolved, and the time taken to give an initial reply.
- During the period, 48 matters were logged, 39 were closed through the process, and 44 received a first response within 10 working days; we also used a separate remedy process for confirmed cases, and 12 cases were fully put right.
Illustrative only: shows how to describe who was engaged, the methods used, whether formal arrangements existed and what they covered, the channels open for concerns, how accessible they were, the key measures tracked, the share resolved, the response timing, and how remedy was handled.
We maintained direct dialogue with warehouse teams, delivery drivers, and labour-hire staff, using different formats so people could speak up in ways that suited their work pattern. We also had written agreements with elected worker representatives for our distribution centres, covering the permanent warehouse workforce and agency staff on those sites; alongside that, we ran a grievance route that was open through kiosks, QR codes, a hotline, and in-person HR drop-ins, with translation support and an option to submit anonymously.
- The route was available at every major site and was designed to be usable by night-shift staff and people without company devices; we monitored how many issues came in, how many were settled, and how quickly people heard back.
- In the year, 27 issues were raised, 20 were resolved, and 24 got an initial reply within 7 working days; for matters needing correction, we used a formal remedy path and completed 9 cases.
Illustrative only: shows a second plausible reporter with different channels and workforce mix, while still covering engagement groups and methods, formal arrangements and scope, open channels, accessibility, tracked measures, resolution share, reply timing, and remediation outcomes.
Quality ladder
- Basic
I have a worker and supplier contact route and a complaints process.
- Better
I have separate contact routes for workers and suppliers, a complaints process for both, and I track how many cases are closed and how quickly we reply.
- Best
I have contact routes for workers and suppliers across our sites and main contractors, a complaints process that is open to both groups, and I report the number of cases closed and our reply times each quarter; the latest period improved because we added a faster triage step and clearer ownership for follow-up.
Check your understanding
Scenarios to work through
A manufacturer has mapped two worker groups for direct dialogue this year: site employees and agency workers at its main plant. It uses toolbox talks for one group and a worker committee for the other, but the committee only covers the day shift.
A food processor has a hotline for complaints from workers and contractors, but it is only available in the local language and can be used only during office hours. The team is unsure whether that is enough to describe the route as accessible.
A retailer tracks the number of issues raised, the share closed within target, and the average days to first reply. One business unit also reports a separate measure for repeat complaints, and the reporting team wonders whether that extra metric should replace the others.
A logistics company says it has a process to fix worker complaints, but in practice supervisors handle issues informally and there is no written path for cases that need escalation. The team has also closed 18 of 30 logged cases this year, but it is unclear whether those 18 were actually put right.
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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
S2-2
within ESRS S2: Workers in the Value Chain
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints list. The page is designed to help you turn those inputs into a draft narrative and, where relevant, a simple table or content-index line.
The page lists the datapoints to prepare, including engagement routes, stakeholder groups, engagement approach, agreed terms, grievance routes, formal process, access conditions, complaint metrics, resolved share, reply timing, fix-up process and closed remedies. Use that list as your collection checklist so you can gather the right inputs before drafting.
Use the step-by-step preparation section to define what is in scope and then align your data collection to the listed datapoints. The page does not set a one-size methodology, so the practical approach is to document your own scope choices clearly and keep them consistent across the narrative, table and evidence pack.
The page is aimed at sustainability and ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can explain the data and provide evidence. In practice, assign a named owner for the disclosure, a data owner for the underlying metrics, and a reviewer for assurance readiness.
The page includes an evidence pack with five items for assurance readiness, alongside five assurance claims to verify. Use those materials to show how the figures and narrative were built, and keep the supporting documents organised so a reviewer can trace each claim back to source evidence.
The page lists common reporting gaps and mistakes, so it is useful as a pre-submission check. A practical use is to compare your draft against the datapoints, the evidence pack and the assurance claims to spot missing detail, weak support or inconsistent wording.
Treat the example as a model for structure and level of detail, not as a template to copy. The page says the example is synthetic and includes a quantitative table, so you can use it to see how a draft might read while still tailoring the content to your own data.
Yes. The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format, which are there to support preparation and assurance readiness. Use them to organise inputs, track evidence and shape the draft output.
The draft-output section gives visualisation ideas, narrative starters and a content-index line. That makes it easier to turn collected data into a usable draft rather than starting from a blank page.
The page includes a 'From company reports' table that links to real published reports at the pages where the topic is disclosed. Use it to see how others have presented similar information, but keep your own disclosure grounded in your organisation’s data and scope.
More questions this page can help with