Disclosure focus
The practical focus is on whether the organisation’s response is broad enough and targeted enough to be credible. That means looking across the relevant parts of the business, not only at a few well-performing sites or headline initiatives, and showing where actions are being rolled out, where they are still limited, and what resources support delivery.
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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Implemented actions
Sustainability / operationsA plain summary of the steps the organisation has put in place, including what was done and at what stage it stands now.
Evidence Action tracker, project updates, management reports, remediation plans.
Watch for The action list is taken from a plan rather than what was actually completed, so planned and implemented actions are mixed up.
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Supplier engagement
Procurement / supplier managementA short description of how the organisation has worked with suppliers on the issue, including the main engagement methods used.
Evidence Supplier communications, meeting notes, procurement records, supplier programme logs.
Watch for Supplier outreach is reported from a central programme list but not reconciled to the suppliers actually contacted, so inactive suppliers are counted.
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Audit activity
Internal audit / complianceA summary of the checks or reviews carried out, including what was examined and the main outcome of those checks.
Evidence Audit reports, internal review files, assurance notes, corrective action logs.
Watch for Audit counts are taken from the audit plan rather than completed reviews, so scheduled and finished audits are mixed.
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Training and support
HR / learning and developmentA description of the capability-building provided, such as training, guidance or support, and who received it.
Evidence Training attendance records, learning materials, workshop logs, HR development records.
Watch for Training is reported from course delivery records but the participant list is not checked, so attendees and invitees are mixed.
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Impact category
Sustainability / riskThe kind of effect being addressed, stated in business terms so the reader can see what sort of issue the action relates to.
Evidence Impact assessment, issue log, case notes, risk register.
Watch for The impact is described using a different internal category set than the one used in the assessment file, so the label does not match the underlying case type.
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Response actions
Sustainability / operationsA summary of the steps taken in response to the issue, including what the organisation actually did and any follow-up measures.
Evidence Remediation plan, case management notes, management actions log, correspondence.
Watch for The response is copied from the intended mitigation plan, so proposed actions are reported as if they had already happened.
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Influence used
Procurement / legalA description of the ways the organisation used its relationship with the supplier, including any contract terms or buying power applied.
Evidence Contract clauses, supplier correspondence, procurement escalation records, commercial review notes.
Watch for Commercial pressure and contractual rights are blended together, so the reported influence method does not match the actual lever used.
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Performance measures
Procurement / supplier performanceThe key measures used to track supplier performance, including the metric name and the period or basis used to calculate it.
Evidence KPI dashboard, supplier scorecard, performance reports, management packs.
Watch for The measure is pulled from a different reporting period or basis than the supplier scorecard, so the KPI does not tie to the source report.
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Supplier scorecard
Procurement / supplier performanceThe supplier’s assessed performance score or rating, including the scoring scale and the period it relates to.
Evidence Supplier scorecard, performance review pack, procurement system record.
Watch for The score is taken from a local spreadsheet rather than the live supplier record, so the reported rating does not reconcile to the source system.
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Audit findings
Internal audit / complianceThe outcome of the audit work, including the main findings, pass/fail result, or any exceptions noted.
Evidence Audit report, assurance statement, findings log, corrective action tracker.
Watch for The result is summarised from the draft report instead of the final signed-off version, so the reported findings do not match the completed audit.
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Incident count
Risk / complianceThe total number of incidents recorded for the reporting period, using one consistent incident definition and one clear cut-off date.
Evidence Incident register, case management system, incident log, escalation records.
Watch for The count mixes incidents from different periods or counts reopened cases twice, so the total does not match the incident register.
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Incident types
Risk / complianceA description of the kinds of incidents recorded, grouped into clear categories that match the incident log.
Evidence Incident register, case notes, classification guide, investigation summaries.
Watch for Incident types are grouped using a different taxonomy than the case log, so the categories do not align with the source records.
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Incident severity
Risk / complianceThe severity level assigned to the incidents, using the organisation’s defined scale and the basis used to judge seriousness.
Evidence Incident register, severity matrix, investigation report, escalation policy.
Watch for Severity is assigned using a different scale than the incident matrix, so low, medium and high cases are not classified consistently.
Before you start
- Have you decided which supplier-side steps, checks and training activity belong in this period’s write-up, and which sit outside it?
- For each action, have you fixed the time basis and the source record you will use so the figures can be traced back?
- When you describe how you influenced suppliers, have you settled whether you mean contract terms, buying power, or both?
- Have you agreed which performance measures, scorecards and audit outputs will be used, and whether they come from the same reporting cut-off?
- Before counting incidents, have you set the scope for what counts as one case and how you will classify its seriousness?
How to prepare it
Request the data
Request supplier action and monitoring evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions have we taken with suppliers, what leverage did we use, and what evidence shows the follow-up, checks, and incident tracking for the reporting period?
Use your own supplier-management language first, then map it to the disclosure. For example, if your team talks about vendor remediation, corrective actions, scorecards, site checks, or supplier incidents, use those terms in the request and only translate them afterwards for reporting.
Weak request
Please provide the ESRS S2:S2-3 actions and resources data for suppliers, including all required datapoints and evidence.
Why it fails: It uses framework language that many operational teams do not use day to day, so the owner may not know which systems, records, or local terms to pull from. It also does not say what period, category, or source file is needed, so the response is likely to be incomplete or hard to map.
Better request
Please send the supplier action and monitoring pack for [reporting period] for [business area / category]. Include the actions taken, supplier follow-up, audits or checks, training or coaching, any contract or commercial levers used, the scorecard or KPI results, and the incident count with type and severity. Use your team’s own wording and add the source system, extract date, and supporting files so we can map it for reporting.
Formal email template
Subject: Request for supplier action and monitoring evidence for [reporting period] Dear [name], We are preparing the sustainability reporting pack and need your help with the supplier-related evidence for [business area / category]. Please share the information below for [reporting period], using your team’s own terms where possible and adding a short note so we can map it for reporting. Please provide: - the main supplier actions completed during the period - any supplier engagement or follow-up activity - any audits, checks, or reviews carried out - any training, coaching, or capability-building provided to suppliers - the main issue types addressed and what was done in response - the commercial or contractual levers used, if any - the KPIs, scorecards, audit results, or other performance measures used - the number of supplier incidents recorded - the incident types and how each was classified for severity Please include the source system or file name, the date the extract was taken, and the person who can confirm the data. If you have supporting documents, please attach them or link them. Please adapt this to your organisation’s own language and check the official source before sign-off. Kind regards, [preparer name]
Short Teams / Slack version
Hi [name] — could you send the supplier action / monitoring evidence for [reporting period] for [business area / category]? Please include actions taken, supplier follow-up, audits/checks, training, any levers used, KPI/scorecard or audit results, and the incident count with type and severity. Add the source system, extract date, and any supporting files. Please use your team’s own terms and we’ll map them for reporting. Thanks.
Industry examples
Manufacturing
Context. A plant team manages direct material suppliers and tracks corrective actions after quality or labour-rights issues.
Adapted request. Please share the supplier corrective-action and monitoring file for [reporting period] covering direct material suppliers. Include remediation actions, supplier follow-up, audit findings, training provided to suppliers, contract levers used, quality or compliance scorecards, and any supplier incidents with severity ratings.
Example response. A spreadsheet listing supplier name, issue category, action taken, follow-up date, audit result, scorecard result, incident count, incident type, severity level, and links to the audit report and corrective-action tracker.
Retail / Consumer Goods
Context. A sourcing team oversees private-label suppliers and uses scorecards, site visits, and commercial escalation when issues arise.
Adapted request. Please send the supplier performance and issue-management summary for [reporting period] for private-label suppliers. Include engagement activity, site visits, audits, training sessions, commercial escalation steps, KPI results, supplier scores, and any incidents recorded with type and severity.
Example response. A monthly pack with supplier scorecards, visit notes, audit summaries, training attendance records, escalation log entries, and an incident register with counts and severity classifications.
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 company defined each supplier-related measure, what data sources were used, the reporting period covered and any rules used to classify actions, performance measures, audit findings and incidents.
Context note
Set out what the figures show about how the company is working with suppliers, how it is tracking supplier performance and what the incident data indicates about the nature and seriousness of issues identified.
Fluctuation statement
If the numbers moved materially, describe the main operational reasons for the change, such as more supplier engagement, a different audit programme, changes in performance scoring or a shift in the mix or seriousness of incidents.
Content index entry
S2-3 Actions & Resources — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S2-3 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We prepared the coverage figure by mapping the disclosed operations and related value-chain activities, then checking that the scope choice was applied consistently across the report.
Risk An assurer may test whether the boundary was set selectively, whether exclusions were justified, and whether the same scope was used wherever the figure is discussed.
Evidence to check Scope memo; boundary map; list of included and excluded entities/activities; management sign-off; cross-checks showing the same scope was used in linked sections and tables.
We linked the actions on transition-related worker impacts to other sustainability topics so the reader can see how the different subjects connect in practice.
Risk An assurer may probe whether the links are real and traceable, or whether the report is presenting separate topics as connected without support.
Evidence to check Draft narrative showing the cross-links; internal mapping between topics; source documents for the linked actions; review notes confirming the connections were checked before publication.
We cross-referenced the incident information to the concern channels and the related action sections so the reader can follow the issue from report to response.
Risk An assurer may test whether the references actually point to the right places, whether the same incident set is used throughout, and whether any material link was omitted.
Evidence to check Hyperlink or page-reference check; incident log; channel records; action tracker; final proof showing the references were tested before issue.
We described the main steps already taken, the steps planned, and the steps still under way to address the negative effects on workers in the supply chain.
Risk An assurer may ask whether the actions are complete, whether timing is clear, and whether the wording overstates what has actually started or been delivered.
Evidence to check Action plan; project tracker; implementation status updates; approvals for planned versus completed actions; evidence that each action was current at the reporting date.
We set out the key measures and the resources assigned to manage the positive and negative effects, risks, and opportunities linked to workers in the supply chain.
Risk An assurer may test whether the resource description is specific enough, whether the measures are truly key, and whether the allocation matches the stated priorities.
Evidence to check Budget and staffing records; programme plans; ownership matrix; management papers showing why the measures were selected as key; internal review of resource allocation.
Where business pressure could have limited the response, we documented the leverage we had, any joint action with others, and how we handled those tensions.
Risk An assurer may probe whether the company really had leverage, whether collective action was used where needed, and whether commercial pressure was downplayed or ignored.
Evidence to check Supplier engagement records; joint initiative documents; escalation notes; decision papers on trade-offs; evidence of how commercial constraints were considered and resolved.
Evidence pack to prepare
Common reporting gaps
- Figures are stated without the supporting narrative, or narrative without figures.
- Scope is inconsistent between the text and the numbers.
- The reporting boundary is left undefined.
- Material changes since the previous period are not disclosed.
- Estimates and measured values are not distinguished.
- Source records for the figures are not identified.
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 a policy or reporting contact instead of the people who actually run supplier engagement, audits, training, or incident tracking, so the data comes back incomplete or second-hand.
- Framework language onlyThe request is sent using disclosure labels rather than the organisation’s own operational terms, and the business cannot map the ask cleanly to its records.
- Unclear boundaryNo one defines which suppliers, sites, contracts, or business units are in scope, so different teams pull different populations and the final set is not comparable.
- Wrong time basisData is gathered using a different period, cut-off, or snapshot date from the one used elsewhere, which makes the figures and narrative impossible to align.
- Mixed counting methodOne source counts events, another counts suppliers, and a third counts actions, but the team combines them without separating the basis, so the totals are misleading.
- Source labels lostThe original names from the system, audit file, or tracker are replaced too early, so later reviewers cannot trace each figure back to the exact source record.
- Populations mergedSuppliers with different risk levels, regions, or treatment paths are rolled into one file even though they should stay separate, which hides the real pattern in the data.
- Missing evidence trailThe team stores the numbers but not the supporting file names, dates, owner details, or approval history, so nobody can show how the dataset was built or checked.
- No sign-off recordThe final extract is circulated without a clear review and approval trail, so there is no reliable record of who checked the data before it was used.
Judgement needed
- Set the reporting perimeter after buy-ins and sell-offsUse the same cut-off date and consolidation logic across the period, and explain any business units added or removed so readers can see why the action list, supplier work and incident counts changed.
- Decide how to handle country-by-country wording differencesWhere local labels or legal categories do not line up, map them to one internal description, state the mapping used, and note any places where the local meaning is broader or narrower.
- Choose whether borderline suppliers are in or outIf a supplier sits near your operational boundary, apply one consistent rule for inclusion, then disclose that rule and any material exceptions so the scope of actions and checks is understandable.
- Fix the timing basis for actions and resultsState whether you are using the position at period end, the full-year average, or another cut-off, and keep that basis consistent for actions taken, audits, training and performance measures.
- Separate what was measured from what was estimatedWhen direct evidence is incomplete, say which figures come from records and which rely on estimates or proxies, and explain the method used to fill the gaps.
- Round numbers without losing the storyApply one rounding rule across the disclosure, and check that rounded subtotals still reconcile to the total so the count of incidents, audits or trained people remains coherent.
- Aggregate sensitive people data carefullyIf privacy rules prevent naming small groups or sites, combine the data to a level that protects individuals, and say that the figures are grouped for confidentiality.
- Explain how overlapping actions are countedWhere one initiative covers more than one issue, describe the counting rule you used so the same work is not double-counted across supplier engagement, audits, capacity building or incident follow-up.
- Clarify how performance scores are builtIf supplier scores come from several checks or weightings, disclose the main inputs and the scoring basis so users can understand what the score reflects and compare it with audit results.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We are using a supplier improvement programme to address labour-rights risks in our cut-and-sew and fabric supply base, and this example is synthetic and for illustration only. - We carried out 24 supplier reviews and 18 site audits across 30 direct suppliers; 12 suppliers received corrective-action plans, 9 completed our training on working hours and grievance handling, and 6 were supported through follow-up coaching. - The main issue type was excessive overtime, alongside wage-payment delays and weak worker voice channels; we used contract terms, order-volume discussions, and escalation meetings to secure remediation, and our supplier scorecard averaged 78/100, with audited sites averaging 82/100 on labour controls and 4 audits showing no major findings, 10 with minor findings, and 4 with significant findings. - During the period we recorded 7 incidents, including 4 overtime breaches, 2 wage-delay cases, and 1 retaliation allegation; we classified 2 as high severity, 3 as medium, and 2 as low.
Synthetic illustration only; figures are invented for training and are internally consistent.
We are applying supplier controls to reduce health-and-safety and forced-labour risks in our agricultural inputs and packaging chain, and this example is synthetic and for illustration only. - We completed 16 supplier engagements and 14 audits across 22 suppliers; 8 suppliers were placed on improvement plans, 11 managers and buyer teams received refresher training, and 5 suppliers took part in joint workshops on recruitment practices and site safety. - The main harm types were unsafe working conditions, recruitment-fee exposure, and restricted freedom to leave employment; we relied on purchasing commitments, contract clauses, and escalation with senior supplier contacts, while our supplier performance index averaged 74/100 and audited suppliers averaged 79/100, with 3 audits clean, 8 showing limited issues, and 3 showing material issues. - We logged 5 incidents in total, made up of 2 safety events, 2 recruitment-fee complaints, and 1 passport-retention case; 1 was classed as severe, 2 as moderate, and 2 as minor.
Synthetic illustration only; figures are invented for training and are internally consistent.
Quality ladder
- Basic
We logged 3 supplier issues this year.
- Better
We logged 3 supplier issues this year, grouped by harm type and tracked against our supplier checks and improvement plan.
- Best
We logged 3 supplier issues across our direct suppliers this year, grouped by harm type and severity, and we used contract terms, buying leverage, audits, KPIs and training to address them; the count was unchanged from last year because we expanded checks to more sites and found more low-severity cases.
Check your understanding
Scenarios to work through
A preparer has a short list of supplier-facing steps for a labour-rights issue: revised contract clauses, a corrective action plan, and extra site visits. The draft also mentions a training budget, but it is not clear whether that budget was actually used this period.
A team has responded to a serious supplier labour issue by tightening purchase terms, increasing follow-up calls, and using its buying power to push for change. The draft report says the issue was “addressed”, but it does not explain what kind of harm was involved or how the company influenced the supplier.
A preparer has performance data from supplier scorecards and audit findings, but the numbers are mixed with narrative comments. One supplier improved on the scorecard after training, while another failed an audit and was given a corrective plan; the draft does not show which evidence supports which part of the story.
A supplier audit found repeated excessive overtime at one site, and the company classifies the issue as serious. The draft mentions one incident, but the team is unsure whether to describe the event as a one-off or as part of a wider pattern, and whether the severity label should be explained.
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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
S2-3
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 and the step-by-step preparation section, then use the listed datapoints to shape your draft. The page is designed to help you organise scope, evidence and ownership before you write the disclosure.
The page lists the datapoints to prepare, including implemented actions, supplier engagement, audit activity, training and support, impact category, response actions and the incident-related measures. Use that list to decide what data you already hold and what still needs to be requested from owners or suppliers.
Use the page as a coordination tool: it points you to the datapoints, the step-by-step preparation process and the evidence pack so you can assign each item to the right business owner. In practice, that usually means separating content owners, data owners and the person assembling the draft.
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those materials to build a file that shows the claim, the risk it addresses and the evidence you can produce.
The page says there are six assurance claims to verify, each linked to a claim, risk and evidence check. Use that section to test whether your draft is supported by traceable records before it goes to review.
The page lists common reporting gaps and mistakes so you can check for missing datapoints, weak evidence or unclear scope before finalising the draft. It is best used as a pre-submission quality check rather than as a substitute for your own controls.
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise the datapoints, evidence and assurance checks, and the PDF as a quick reference while drafting.
The page includes synthetic illustrative examples and a quantitative table to show how the disclosure can be turned into a draft. Treat them as formatting and content examples only, not as real-world benchmarks or required wording.
The draft-output section gives visualisation ideas, narrative starters and a content-index line to help you convert your data into report-ready text. Use those prompts to keep the narrative tied to the datapoints and evidence you have collected.
The page has a 'From company reports' table that links to published reports where the topic is disclosed. Use it to see how others present the topic, but keep your own draft grounded in your organisation’s data and evidence.
More questions this page can help with