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London Reporting Academy ESRS S3 · Affected Communities · Disclosure Requirement S3-2

Applicable from FY2027

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

Engagement & Grievance Mechanisms

S3-2 · mandatory · narrative disclosure

This disclosure asks an organisation to explain how it engages with the people in its own workforce and how those people can raise concerns or complaints. In practice, the report should show whether workers have accessible ways to speak up, whether those channels are available in the places and parts of the business where people actually work, and how the organisation responds when issues are raised.

Disclosure focus

The practical focus is on coverage and effectiveness, not just the existence of a policy. An organisation should describe whether its approach reaches all relevant workers across operations, sites and employment arrangements, or only selected locations, and how it makes the process usable in day-to-day work. The emphasis is on whether workers can use the mechanism safely and whether the organisation learns from what it receives.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Engagement routes

    Sustainability / stakeholder engagement

    List the ways people can raise issues or share views, such as meetings, hotlines, digital forms, site visits, or representative forums.

    Evidence Stakeholder engagement plan, channel register, meeting calendar, communications materials.

    Watch for Channel list does not reconcile to the actual engagement plan, so a live route used by stakeholders is left out.

  • Affected groups

    Sustainability / human rights

    State which groups were identified for engagement, including women, migrants, and disabled people where relevant, and note the basis used to identify them.

    Evidence Stakeholder mapping, inclusion assessment, consultation notes, community profile.

    Watch for Group list is based on a generic stakeholder map and misses a sub-population that was actually identified in the assessment.

  • Engagement approach

    Sustainability / stakeholder engagement

    Describe the methods used to engage people, such as interviews, workshops, surveys, focus groups, or representative discussions, and how they were applied.

    Evidence Engagement methodology note, workshop packs, survey instruments, attendance records.

    Watch for Method description does not match the records from the engagement exercise, so the reported approach is not the one actually used.

  • FPIC status

    Legal / human rights

    Record whether free, prior and informed consent was applied for the relevant activity, using a clear yes or no based on the documented process.

    Evidence Consent records, project approvals, consultation file, legal or community sign-off log.

    Watch for The yes/no flag is set without checking the project file, so the status is wrong for the actual consent process used.

  • Consultation process

    Sustainability / community relations

    Explain how consultation was carried out, including who was consulted, when it happened, and the steps followed from start to finish.

    Evidence Consultation plan, agendas, minutes, attendance lists, correspondence trail.

    Watch for Process narrative mixes draft plans with completed meetings, so the reported sequence does not match the consultation record.

  • Design participation

    Sustainability / stakeholder engagement

    Describe how affected people took part in shaping the engagement design, including what input they gave and how it influenced the final setup.

    Evidence Co-design workshop notes, participant feedback, revised engagement plan, decision log.

    Watch for Participation is described as broad involvement, but the evidence only shows review after the design was already fixed.

  • Grievance routes

    Legal / compliance

    Set out the ways complaints or concerns can be submitted, including formal and informal routes available to relevant parties.

    Evidence Grievance procedure, hotline details, web form screenshots, site noticeboards, worker handbook.

    Watch for Available routes are taken from policy text and do not reconcile to the channels actually open at sites or in operations.

  • Grievance system

    Legal / compliance

    Confirm whether a formal complaint-handling system exists for the relevant people, using a clear yes or no based on the live process.

    Evidence Grievance policy, case management system, escalation workflow, training records.

    Watch for The yes/no answer is based on policy existence rather than the live case system, so the mechanism status is misclassified.

  • Access conditions

    Legal / compliance

    Describe how people can use the complaint route in practice, including language support, anonymity options, disability access, location, and any other barriers removed.

    Evidence Accessibility review, translated materials, alternative format records, site access checks, user guidance.

    Watch for Accessibility is described in general terms, but the actual route still has a language or disability barrier that was not captured.

  • Grievance metrics

    Legal / compliance

    Provide the key measures tracked for the complaint process, such as volumes, categories, open and closed cases, and other performance measures used internally.

    Evidence Case dashboard, monthly KPI pack, management report, grievance log extract.

    Watch for The KPI set is lifted from a summary report and does not reconcile to the case log, so one measure is missing or defined differently.

  • Case closure rate

    Legal / compliance

    Report the share of cases that were resolved or closed within the chosen period, with the numerator and denominator defined the same way as the case log.

    Evidence Grievance register, closure report, KPI calculation sheet, case status extract.

    Watch for Resolved cases are counted using a different status definition from the case register, so the closure rate is not comparable to the source system.

  • Complaint turnaround

    Legal / compliance

    State how long it takes to respond to complaints, including the timing basis used, the period covered, and whether the measure is average, median, or another basis.

    Evidence Case timestamps, service-level report, dashboard calculation, workflow audit trail.

    Watch for Response time mixes first reply and final closure timing, so the measure is not aligned to the case timestamps.

  • Remedy approach

    Legal / human rights

    Describe the way harm is addressed, including the steps used to fix, compensate, restore, or otherwise respond to the issue.

    Evidence Remediation policy, case files, corrective action tracker, settlement or repair records.

    Watch for The remedy description is generic and does not match the actual corrective action taken in the case file.

  • Remediated cases

    Legal / human rights

    List the cases or incidents that were addressed through the remedy process during the reporting period, with enough detail to identify each one.

    Evidence Case register, remediation tracker, closure notes, incident log.

    Watch for Cases are counted outside the reporting period, so the list includes matters opened or closed in the wrong timeframe.

Before you start

  • Which worker groups are actually covered here — for example women, migrant workers, or disabled workers — and which engagement routes do we need to describe?
  • Have we used the right consultation route for any free, prior and informed consent case, and do we need to explain how people took part in shaping it?
  • Do we have a live complaints route for this workforce, and can we describe how people can reach it and whether it is easy to use?
  • Are the performance figures we plan to show based on the same reporting period and the same internal source across the whole section?
  • Can every number or statement be traced back to a named system, log, or record that we can show on request?
  • Have we settled the definitions for what counts as a case handled, a resolved case, and a response time before we draft the figures?
+ Show S3-2 sub-elements (LRA working checklist)

How to prepare it

Set the reporting boundary first. Decide which parts of the business, sites, operations, and value chain activity are in scope for this disclosure, so the later evidence and wording all relate to the same population.
Map the people and contact routes you need to describe. Identify the worker groups covered by the datapoints, then list the ways they can engage with the organisation and the methods used to do so.
Check whether free, prior and informed consent applies, and if so, record the consultation trail. Note how the process was run and how workers or their representatives were involved in shaping the engagement design.
Gather the operational records behind the disclosure. Pull together the channels available, whether the mechanism exists, how accessible it is, and the measures used to track performance, including the indicators for resolution and response timing.
Prepare the narrative on follow-up and outcomes. Explain the approach used to address issues raised, and summarise the cases that were handled during the reporting period.
Before finalising, reconcile the draft against the source material. Confirm that any exclusions, scope changes, or wording choices are explained, and check that each required item is supported by the official source and the underlying evidence.

Request the data

Request the site 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 that affected local people and other relevant groups were engaged, and that concerns were handled through accessible channels with follow-up and remedy where needed?

Use your organisation’s own terms first, then map them to the reporting labels. For example, if you call these ‘community contacts’, ‘site feedback routes’, ‘hotline cases’ or ‘issue logs’, keep that language in the request and in the return pack; only translate into the reporting wording at the end. Check the source material before sign-off.

Weak request

Please provide the ESRS S3-2 engagement and grievance mechanism disclosures for the year, including stakeholder engagement, FPIC, accessibility, KPIs, remediation and cases addressed.

Why it fails: This 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 too many concepts without saying which internal systems, site boundaries, or local terms to use, making the response harder to verify and map.

Better request

Please send the site/community contact routes, the groups you have identified for tailored engagement, the ways you engaged them, any consent process used, the way people helped shape the engagement plan, the concern-reporting routes, accessibility features, the case-handling measures you track, the remedy approach, and example cases for [period] and [sites in scope]. Use your own team language first, then add a short mapping note and attach the source files.

Formal email template
Subject: Request for site engagement and issue-handling evidence for [reporting period]\n\nHi [name/team],\n\nI’m pulling together the sustainability reporting pack and need your help with the evidence for [sites / operations in scope]. Please send the information you hold on how we engage with affected local groups and how concerns are received, tracked, resolved, and followed up.\n\nPlease use your own operational terms in the return, then add a short mapping note so we can translate them for reporting. If you have more than one source, please include the main one and note any supporting files.\n\nCould you please provide:\n- the channels or routes people can use to contact us\n- the groups you have identified as needing tailored engagement\n- the methods used to engage them\n- whether any free, prior and informed consent process was used, and how it was run if applicable\n- how people were involved in designing the engagement approach\n- the channels available for raising concerns\n- whether a formal handling mechanism exists and how accessible it is\n- the measures you track for case handling\n- how issues are remedied\n- examples of the types of cases handled during [period]\n\nPlease return this by [date] in the table format below, with any supporting evidence attached. If anything is unclear, I’m happy to talk it through. Please check the source material before sign-off.\n\nThanks,\n[Your name]
Short Teams / Slack version
Hi [name] — could you send over the site/community engagement and issue-log evidence for [period] for [sites in scope]? Please use your own team terms, then map them for reporting. I need the channels, groups identified, engagement methods, any consent process used, how the approach was designed, the complaint/concern routes, accessibility, KPIs, remedy approach, and example cases. Please share by [date] with any supporting files. Thanks.

Industry examples

Mining / Extractives

Context. A remote site with nearby villages, seasonal workers, and indigenous communities

Adapted request. Please provide the community liaison logs, village meeting notes, grievance register, and any consent records for [period] covering [site]. Include the contact routes, the groups identified for tailored engagement, the engagement methods used, how the process was designed with local participation, the complaint routes, accessibility arrangements, response and closure measures, remedy actions, and example cases.

Example response. Returned pack includes a community log, meeting attendance sheets, a hotline dashboard, a note confirming a consent process for one land-use activity, accessibility arrangements in two local languages, average first response time, closure rate, and three anonymised case summaries with remedy actions.

Food manufacturing

Context. A plant with migrant labour, disabled workers, and nearby residents affected by traffic and noise

Adapted request. Please send the site feedback routes, worker-rep meeting notes, local resident contact log, and case tracker for [period] at [plant]. Include the groups you have identified, the engagement methods, any consent process used for affected groups where relevant, how the engagement plan was shaped, the channels available for concerns, accessibility features, the KPIs you track, the remedy approach, and examples of cases handled.

Example response. Returned pack includes a shared mailbox, a multilingual phone line, monthly worker-rep meetings, a resident contact log, accessibility notes for translated materials and out-of-hours calls, a dashboard showing open and closed cases, and examples of noise and transport complaints with corrective actions.

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 the basis used to define the affected groups, the engagement channels and methods counted, how consent and consultation were assessed, what was treated as an available access route, and how performance measures and case handling were compiled.

Context note

Set out what the figures show about how the organisation engaged with affected people, how easy it was to raise issues, how quickly matters were handled, and how many cases were taken through to resolution or other remedy.

Fluctuation statement

If any figures moved materially, link the change to shifts in outreach, access, participation in design, case volumes, or the speed and success of handling, and note any operational or process changes that may have influenced the result.

Content index entry

S3-2 Engagement & Grievance Mechanisms — [location / page] / [notes]

Download Centre

Preparation tools & forms

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Check

For each claim, check the evidence

  • We based the coverage figure on the communities and sites we actually reviewed this year, and we excluded any areas where we did not have enough reliable information to support the number.

    Risk An assurer may test whether the coverage boundary was set consistently, whether any exclusions were justified, and whether the figure could be overstated by leaving out harder-to-reach locations or groups.

    Evidence to check Coverage methodology note; list of included and excluded communities/sites; working papers showing how the figure was calculated; management sign-off on boundary decisions; explanation for any gaps or estimates.

  • We used direct input from people affected by the disclosed operations, plus recognised local representatives or trusted intermediaries where direct contact was not practical, and we used that input when deciding our actions during the year.

    Risk An assurer may probe whether the engagement actually happened, whether the people consulted were relevant and credible, and whether their views were reflected in decisions rather than noted only for form.

    Evidence to check Engagement plan and attendance records; meeting notes or interview summaries; records of representatives/proxies used and why; examples showing how feedback influenced decisions, actions, or priorities; internal approvals referencing the input.

  • For groups that may face greater barriers or harm, we gathered additional context through targeted discussions and local sources so the narrative reflects their situation rather than a generic summary.

    Risk An assurer may check whether the extra insight was genuinely obtained from the affected groups, whether the approach was suitable for more vulnerable people, and whether the disclosure overstates the depth of insight.

    Evidence to check Targeted engagement records; notes from local organisations or community contacts; evidence of tailored methods used for harder-to-reach groups; internal review of whether the information was sufficient and balanced; any limitations disclosed internally.

  • We described the complaint routes available to communities, including whether a formal grievance route exists, based on the channels that were operating at the reporting date.

    Risk An assurer may test whether the channels were actually available, whether the description matches current practice, and whether the statement about a formal route is accurate and complete.

    Evidence to check Current process maps or policy documents; screenshots, hotline details, or public notices; operating logs showing the channels were live; legal or compliance review of the wording; evidence of any changes made before publication.

  • We assessed how well the complaint routes work by checking whether people know about them, can use them without undue difficulty, receive timely responses, and can trust the process.

    Risk An assurer may examine whether the assessment used sensible criteria, whether the checks were performed in practice, and whether the conclusion is supported by evidence rather than assertion.

    Evidence to check Effectiveness review or KPI pack; user awareness or accessibility checks; response-time and closure data; sample case files; survey or feedback results; management conclusions and follow-up actions.

  • Where our activities touched indigenous peoples, we recorded whether and how they were consulted on the way engagement was organised and on the practical terms used for that engagement.

    Risk An assurer may probe whether consultation on engagement design really occurred, whether the description is specific to the relevant groups, and whether the record is complete for the reporting period.

    Evidence to check Consultation records; correspondence on engagement design and logistics; meeting minutes; evidence of who was consulted and when; internal review confirming the description matches the underlying records.

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, so the answer comes from a function that does not run the channel, case handling, or follow-up process.
  • Framework terms onlyThe request is written in reporting language instead of the organisation’s own operational terms, and the source team cannot map it to their day-to-day records.
  • Scope left vagueNo one defines which sites, teams, worker groups, or service lines are in scope, so different people collect different populations.
  • Wrong time basisThe data pull uses a different period or cut-off from the one used elsewhere, which makes the figures impossible to compare cleanly.
+ Show 5 more

Judgement needed

  • Which sites and teams count after a buy-in or saleState the cut-off date you used for adding or removing locations, and explain whether the channels, complaints and follow-up cases from the changed perimeter were included on a full-period or partial-period basis.
  • How to handle country-specific labels for the same worker groupIf local records use different labels for the same people, explain the mapping you applied and keep the group split consistent so readers can see who was counted in each category.
  • People just outside the formal workforce boundarySay whether contractors, agency staff, seasonal workers or other near-boundary groups were included in the channel and complaint counts, and explain the rule used to decide any borderline cases.
  • Choosing the timing basis for activity and case countsDisclose whether you used opening, closing or average headcount, and whether engagement and grievance figures reflect events recorded when they happened or when they were closed.
+ Show 5 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 — Food processing

We run regular two-way contact with affected people through site meetings, worker representatives, a multilingual hotline and community drop-ins; in this period we focused on women, migrant workers and disabled people, and used interviews, small-group discussions and anonymous feedback forms to shape the process. For land-related matters, we used a consent-led approach where relevant, held prior discussions with the people concerned, and involved them in designing how the engagement would work; our grievance route was open by phone, web and in person, with 96% of 25 cases closed, 92% of them accessible through the channels we provide, and an average first reply within 3 working days. Where harm was identified, we used direct remedy, service restoration or compensation, and during the period we handled 25 cases in total.

Synthetic illustration for practitioner review only; figures are internally consistent and not based on a real reporter.

Illustrative (synthetic) example — Renewable energy

We kept dialogue open through project briefings, local liaison sessions, a worker forum and a dedicated email line; the groups we paid particular attention to were women, migrant contractors and disabled people, and we used one-to-one conversations, facilitated workshops and written submissions to gather views. For a project affecting customary land, we applied a consent-based process where needed, consulted before key decisions, and invited community members into the design of the engagement plan; our concern-handling route offered email, phone and an online form, was available in plain language and accessible formats, and closed 18 of 20 matters in the period, with 90% resolved and an average reply time of 2 working days. When issues arose, we used apology, corrective action, reinstatement or payment as appropriate, and we dealt with 20 cases overall.

Synthetic illustration for practitioner review only; figures are internally consistent and not based on a real reporter.

Quality ladder

  • Basic

    I have a worker feedback route and a case-handling process in place.

  • Better

    I have a worker feedback route and case-handling process in place for women, migrants and disabled people, using site meetings, phone lines and written reports, and I track how many cases are closed and how quickly we reply.

  • Best

    I have a worker feedback route and case-handling process in place across all sites this year for women, migrants and disabled people, with site meetings, phone lines and written reports, and I use a separate consent-led approach where relevant; we closed 18 of 20 cases and answered most within 10 working days, with the two open cases still under review because they need further evidence and follow-up.

Check your understanding

Scenarios to work through

A preparer is drafting the section on how the organisation speaks with affected people. They have one general staff hotline, plus a separate route used by migrant workers through a local support group, and they are unsure whether to mention both.

QHow should they decide what to include about the ways people can raise issues and the groups that were identified as needing different routes?
Reveal model answer →

A site expansion may affect an Indigenous community, and the project team held meetings, shared translated materials, and allowed time for the community to discuss the plan internally before responding. The preparer is unsure whether to describe this as a simple consultation note or as a more specific consent-related process.

QWhat should they check before deciding how to present the engagement process for this case?
Reveal model answer →

The organisation has a complaints route through a phone line, a web form and an in-person desk at one facility, but workers in another location say the web form is hard to use because of poor connectivity and low literacy. The preparer is deciding whether the section can simply list the channels or whether it needs more detail.

QWhat should they include about the grievance route and its accessibility?
Reveal model answer →

The complaints log shows 40 cases opened in the period, 28 closed, and 12 still open at period end. Of the 28 closed cases, 20 were resolved through corrective action and 8 were closed because the issue was outside scope; the average first response time was 5 days. The preparer is unsure how much of this belongs in the disclosure.

QHow should they decide what to say about performance, closure outcomes and follow-up action?
Reveal model answer →
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