Disclosure focus
The practical focus is on whether these channels are available, usable and relevant in the places and services where impacts can happen, and whether the organisation uses the feedback to identify and address issues. A good explanation should make clear the scope of coverage, how people can access the mechanism, and how the organisation handles and tracks what comes in.
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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Available reporting routes
Grievance/complaints teamList the ways people can raise an issue or ask for help, such as phone, email, web form, in-person desk, hotline, or other internal route. Note which routes are open to which groups and whether any are only for certain locations or languages.
Evidence Policy or procedure, intranet/public contact page, hotline setup, case-management intake options, local site notices.
Watch for Channel list does not reconcile to the live intake routes actually open to users, so a route in use is left out or a closed route is still shown.
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Complaint route in place
Grievance/complaints teamConfirm whether there is a formal way to submit complaints, and capture the yes/no position used for reporting. Keep the decision tied to the organisation’s actual process, not to informal escalation paths.
Evidence Complaints policy, process map, case-management workflow, governance approval for the mechanism.
Watch for Boolean is set from an informal escalation path rather than the formal complaints process, so the reported answer does not match the actual mechanism.
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Access arrangements
Grievance/complaints teamDescribe how people can use the reporting route without undue barriers, including language support, disability access, alternative formats, anonymity options, or local adaptations where relevant.
Evidence Accessibility review, website/app checks, translated materials, disability access assessment, user guidance.
Watch for Accessibility description misses a sub-population or local adaptation, so the stated access arrangements do not match what is actually available to users.
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Complaint metrics
Grievance/complaints teamCapture the measures used to track the reporting route, such as counts, volumes, trends, or other performance indicators the organisation uses to monitor use and handling of complaints.
Evidence Case-management reports, dashboard extracts, KPI pack, management reporting schedule.
Watch for Metrics are pulled from a different source or period than the case log, so the KPI set does not reconcile to the underlying complaint records.
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Resolved case rate
Grievance/complaints teamState the proportion or count of matters that were brought to a close within the reporting period, using the organisation’s chosen basis consistently and explaining the basis if needed.
Evidence Case closure report, case-management export, calculation workbook, reporting methodology note.
Watch for Closed cases and open cases are mixed, or the numerator and denominator use different periods, so the reported resolution rate is not on a consistent basis.
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Reply timing
Grievance/complaints teamCapture how quickly the organisation responds to complaints, including the measure used, the time basis, and any split between first reply and later updates if the organisation reports both.
Evidence Case timestamps, service-level report, workflow logs, reporting calculation file.
Watch for Response timing is calculated from the wrong timestamp or period, so first response and later follow-up timing are conflated.
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Fixing approach
Grievance/complaints teamDescribe the organisation’s approach to putting things right after a complaint or issue is upheld, including the types of remedy used and how decisions are made about them.
Evidence Remediation policy, case notes, decision matrix, closure templates, governance approvals.
Watch for The stated remedy approach does not match the actions recorded in case files, so the narrative is not aligned to actual remediation practice.
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Remedied matters
Grievance/complaints teamCapture the cases that were actually put right during the period, using the organisation’s definition of addressed or remediated cases and the basis for counting them.
Evidence Case-management export, closure status report, remediation tracker, calculation workbook.
Watch for Addressed cases are counted using a different closure status or period than the case tracker, so the total does not reconcile to the underlying records.
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Stakeholder contact methods
Stakeholder engagement teamList the ways the organisation engages with stakeholders, such as support lines, surveys, meetings, interviews, forums, or digital feedback tools, and note which groups each method reaches.
Evidence Engagement plan, survey schedule, meeting logs, stakeholder map, communications records.
Watch for Engagement methods are reported from the plan rather than actual activity, so a channel used in practice is omitted or a dormant channel is still shown.
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At-risk groups
Stakeholder engagement teamIdentify the groups the organisation has recognised as needing extra care or tailored engagement, and record the basis used to classify them as vulnerable or at risk.
Evidence Stakeholder assessment, risk register, inclusion review, engagement plan, issue logs.
Watch for The identified groups do not match the organisation’s own vulnerability assessment, so a relevant sub-population is missed or misclassified.
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Engagement approach
Stakeholder engagement teamDescribe the methods used to engage stakeholders, including how the organisation gathers views, tests issues, and follows up, with enough detail to show the practical approach rather than a generic statement.
Evidence Engagement methodology, consultation plan, workshop notes, survey instruments, meeting records.
Watch for The method description is generic and does not reconcile to the actual engagement activities run in the period, so the reported approach is overstated or incomplete.
Before you start
- Have you decided which staff, contractors, customers, communities, or other affected groups are actually covered by this section, and which are not?
- For the figures and descriptions you will use, have you fixed the reporting period and the basis for counting so the numbers line up across the whole pack?
- Can every channel, case count, response measure, and resolution figure be traced back to a named internal source or record?
- Have you agreed what counts as a feedback route, a complaint route, and a remedy route in your organisation’s own operating language?
- For any groups you treat as more exposed or harder to reach, have you settled the criteria you will use to identify them and the methods you will describe?
- Before you draft the narrative, have you confirmed which performance measures you will include and how you will define them consistently for this report?
How to prepare it
Request the data
Request the complaints, feedback and engagement log from Operations
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What channels do we use to hear from affected people, how do we handle issues raised, and what evidence shows the process is working in practice?
Use your organisation’s own terms first, then map them to the disclosure. For example, if you call these routes ‘customer contacts’, ‘case management’, ‘whistleblowing’, ‘community feedback’ or ‘service recovery’, use those labels in the request and only translate them afterwards for reporting.
Weak request
Please provide the ESRS S4-2 engagement and grievance mechanism evidence, including stakeholder engagement channels, vulnerable groups, accessibility, KPIs, remediation approach and cases addressed.
Why it fails: This uses framework language that many operational teams do not use day to day, so it can be hard to answer consistently. It also does not say which systems, labels, time period, or business areas to pull from, so the response may be incomplete or not comparable.
Better request
Please send the complaints, feedback and case-handling records for [period] from [system/team]. We need the routes people use to contact us, whether there is a formal complaints route, how those routes are made accessible, the measures you track on response and closure, how issues are fixed, and the main case types. Please use your own team labels and add a short mapping note to the reporting categories.
Formal email template
Subject: Request for complaints, feedback and engagement data for [reporting period]\n\nDear [name/team],\n\nWe are preparing the sustainability reporting pack and need your help with the records that show how people can raise concerns or give feedback, and how those cases are handled.\n\nPlease send, for [reporting period] and for [sites/business units in scope]:\n- the channels people can use to contact us or raise an issue;\n- whether a formal complaints route exists;\n- how those routes are made accessible;\n- the measures you track on case handling and closure;\n- how issues are corrected or otherwise followed up; and\n- a summary of the types of cases handled.\n\nPlease use your team’s own wording in the first instance. If helpful, add a short note explaining how your internal labels map to the reporting categories.\n\nPlease also include the source system, report date, owner, and any supporting documents or dashboard extracts. If there are gaps, please flag them clearly.\n\nThis is a possible LRA training template; please adapt it to your organisation and check the official source before sign-off.\n\nMany thanks,\n[preparer name]
Short Teams / Slack version
Hi [name] — could you share the complaints / feedback / case-handling data for [period] across [scope]? We need the channels used, whether there is a formal complaints route, accessibility features, the main KPIs, how issues are remedied, and the case types handled. Please use your internal labels and add a short mapping note if needed. Include the source system and any dashboard/export links. This is a possible LRA training template; adapt it to your organisation and check the official source before sign-off.
Industry examples
Retail / Customer Operations
Context. A retailer receives customer complaints through stores, call centres, web chat and social media escalation.
Adapted request. Please share the customer contact and complaints log for [period] across stores, contact centre and digital channels. Include the route names customers use, whether there is a formal complaints process, accessibility options, the service KPIs you track, how issues are resolved, and the main complaint types. Please use your own operational labels and add a mapping note.
Example response. A table exported from the case system showing channel, complaint route flag, accessibility support, case type, open/closed counts, average response time, average close time, resolution rate, remedy type and escalation notes, plus links to the service recovery dashboard and process note.
Manufacturing / Site Operations
Context. A manufacturer gathers worker and contractor concerns through site briefings, supervisor escalation, hotline and suggestion boxes.
Adapted request. Please provide the site concerns and escalation log for [period] for all in-scope plants. Include the routes available to workers and contractors, whether there is a formal complaints route, how access is supported for different groups, the measures used to track handling times and closure, how issues are corrected, and the main issue categories. Use site terms first, then map them for reporting.
Example response. A site-level spreadsheet listing hotline, supervisor, union rep and suggestion box routes; accessibility arrangements; issue categories; cases raised and closed; average response and closure times; remedy actions; and evidence links to the hotline procedure and monthly site dashboard.
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 which people-related channels were counted, how the organisation defined a complaint route, what was included in accessibility and response measures, and the basis used to identify vulnerable groups and cases handled through remedy processes.
Context note
Set out what the figures show about how people can raise issues, how the organisation engages with them, and how effectively concerns are being handled and put right.
Fluctuation statement
If the figures moved from the previous period, link the change to shifts in channel availability, engagement activity, case volumes, response speed, resolution performance, or the number of matters taken through remediation.
Content index entry
S4-2 Engagement & Grievance Mechanisms — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S4-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We based the coverage figure on the population we actually reviewed, and we can show how we drew the boundary, excluded any out-of-scope parts, and avoided double counting.
Risk An assurer will probe whether the reported coverage is complete, whether the boundary was set consistently, and whether exclusions or overlaps could make the figure look stronger than it is.
Evidence to check Boundary memo or methodology note; population lists or system extracts used for the calculation; reconciliation showing included and excluded items; working papers showing how duplicates were removed; sign-off from the preparer and reviewer.
We used our usual engagement routes with customers and users, and we can evidence how those routes were selected, who was consulted, and how we handled input from representatives or other credible intermediaries.
Risk An assurer will check whether the engagement approach was real and representative, or whether it missed relevant voices or relied on a narrow set of contacts.
Evidence to check Engagement plan; meeting notes, call logs, survey outputs, or consultation records; stakeholder mapping; records showing use of representatives or proxies where direct contact was not practical; internal summary of themes raised and how they were assessed.
Where we needed insight from people who may face barriers, we used targeted methods rather than relying only on standard channels, and we can show how those methods were chosen and what they captured.
Risk An assurer will test whether the process genuinely reached harder-to-hear groups and whether the evidence supports the claim that their views informed the disclosure.
Evidence to check Targeted outreach plan; records of adapted engagement methods; evidence of accessibility adjustments, translation, or facilitated sessions where used; anonymised feedback summaries; internal review showing how the insights were incorporated.
We described our response process only after checking that we had evidence of how issues were logged, triaged, escalated, and closed, including cases where we worked with others to put things right.
Risk An assurer will look for whether the remediation description is backed by actual process records and whether the company can demonstrate that it can act on material harm, not just talk about it.
Evidence to check Case management records; escalation and closure logs; remediation procedure; examples of completed cases; correspondence showing cooperation with third parties where relevant; approval notes confirming the process description matches practice.
Before publishing, we tested whether the contact routes were usable in practice by checking response times, accessibility, follow-up rates, and whether users could raise issues without fear of negative treatment.
Risk An assurer will probe whether the effectiveness assessment was meaningful, whether the measures used were appropriate, and whether the channels were genuinely usable for intended users.
Evidence to check Channel performance dashboard or KPI pack; test results or user journey checks; accessibility review; complaint or query statistics; internal assessment against the chosen criteria; evidence of any improvements made before publication.
We used feedback from customers and users to shape actions during the year, and we can trace specific themes from the input to the decisions or activities that followed.
Risk An assurer will check whether the link between feedback and action is real, or whether the disclosure overstates how much user input influenced decisions.
Evidence to check Issue tracker or action log; meeting minutes showing discussion of user feedback; decision papers referencing the input; before-and-after examples of changes made; management review notes linking themes to actions.
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 request goes to the wrong team, so the data is chased from people who do not run the support line, survey process, or case-handling log.
- Framework language usedThe data call is written in reporting jargon instead of the organisation’s own terms, so staff cannot map it to the actual helpdesk, feedback route, or case register.
- Scope not fixedNo one states which business units, sites, or service lines are in scope, so different teams send different slices of the same activity.
- Boundary driftThe collector mixes internal channels with third-party or legacy routes without saying which population belongs in the count, so the dataset is not comparable.
- Wrong period basisPeople pull figures from different cut-off dates or reporting windows, so the channel list, case counts, and timing measures do not line up.
- Mixed counting basisOne team reports unique cases while another reports contacts or actions, and the final file combines them as if they were the same measure.
- Source labels lostThe original names from the intake form, tracker, or case system are stripped out, so later reviewers cannot trace each figure back to its source record.
- Evidence metadata missingThe file is saved without the date, owner, version, or system reference, so no one can tell which extract was used or whether it was current.
- No sign-off trailThe numbers are passed on without a named reviewer or approval step, so there is no clear record of who checked the data before it moved into drafting.
Judgement needed
- What counts as a live route for concernsList only the routes people can actually use in the reporting period, and explain any local hotlines, web forms, union routes or site-level channels that are available in some places but not others.
- Whether a route is a complaint channel or just a feedback routeIf a route can receive concerns but is not set up to handle complaints end to end, say so plainly and describe how you separate it from the formal case-handling route.
- How to handle different local names for the same processWhere country teams use different labels for similar ways of raising issues, map them to one internal description and disclose the local differences so readers can see what is comparable and what is not.
- Which people are included when the boundary shiftsWhen acquisitions, disposals or reorganisations change the group of people covered, state the cut-off used and explain whether the figures reflect the opening, closing or average scope for the period.
- How to treat people just outside the formal scopeIf some workers, contractors, agency staff, supply-chain workers or community members can use the route even though they sit near the boundary, explain whether they are included in the channel description and in the case counts.
- Choosing the basis for response and closure timingPick one timing basis for first reply, resolution and closure, apply it consistently, and disclose the rule used where a case spans month-end, year-end or multiple teams.
- Using estimates where case records are incompleteIf the case log does not fully support a metric, use a clearly stated estimate method, identify the data gaps, and separate estimated figures from directly counted ones.
- How to present rates and percentagesState the denominator behind any rate, share or percentage, and explain any rounding so readers can reconcile the headline figure with the underlying case totals.
- How much detail to show when privacy limits the dataWhere small numbers or sensitive case details could identify people, group the information to a safer level and say that the presentation has been reduced for confidentiality reasons.
- Whether to combine or separate linked routes and outcomesIf one concern can move between a local route, a central case team and a remedy process, explain whether you count it once or in several places and how you avoid double counting.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We ran a mix of direct conversations, short staff surveys and targeted outreach to people in higher-risk situations, and we used those inputs to shape our approach with affected communities. In the year, we identified 3 vulnerable groups and used 4 engagement routes: store-based help desks, a phone line, an online form and community partner sessions.
- We had a formal complaints route in place, with 5 access points available; 4 were designed to be easy to use for people with different needs, and 1 required extra support.
- We logged 120 complaints, resolved 102 of them during the period, and closed them in an average of 18 days.
- Where harm was confirmed, we used case-by-case remedies such as refunds, service fixes, apology letters and follow-up checks; 27 cases were handled through that process.
This synthetic example shows how to describe the channels used to hear from affected people, who was prioritised as more exposed to harm, and how feedback was gathered. It also illustrates reporting on the complaint route, how usable it was, the number of cases, the share resolved, the average turnaround, and the kinds of remedy applied.
We combined patient forums, anonymous pulse surveys and meetings with carers to understand concerns and to keep contact open with people most likely to face barriers. We identified 2 vulnerable groups and used 3 engagement methods: clinic drop-ins, a digital survey and a partner-led listening session.
- Our complaint system offered 4 ways to raise an issue; all 4 were accessible, and the route was available throughout the reporting period.
- We received 84 complaints, settled 63 within the period, and took an average of 11 days to respond and close them.
- For confirmed cases, we used practical redress such as treatment rebooking, fee waivers, service corrections and direct follow-up; 19 cases were dealt with in this way.
This synthetic example shows a different sector using a smaller set of outreach methods and a different complaint profile. It covers the same disclosure points: who was engaged, which groups were seen as more exposed, how feedback was collected, what complaint options existed, how accessible they were, and how many cases were remedied.
Quality ladder
- Basic
We had a grievance route in place and received 18 cases.
- Better
We used helplines, surveys and manager check-ins, and our grievance route handled 18 cases with 15 closed and a median reply time of 6 days.
- Best
Across our sites this year, we used helplines, surveys and manager check-ins to reach staff and other affected people, kept a grievance route open, handled 18 cases, closed 15 within a median 6 days, and the slower closure pace reflected a higher share of complex cases needing follow-up.
Check your understanding
Scenarios to work through
A service team has a staff helpline, an online form, and quarterly listening sessions. A preparer is drafting the disclosure and notices that the form is only available in one language, while some workers mainly use another language at work.
A grievance log shows 40 cases opened in the year, 28 closed, and 12 still open at year-end. The draft narrative says the process is effective because most matters were handled, but it does not mention how long people waited for a first reply.
The company has a formal complaint route for workers and contractors, plus a separate community hotline for nearby residents. During the year, a case involving a contractor’s safety concern was handled through the worker route because the hotline team redirected it internally.
A preparer is writing the section on engagement with affected people. The company held six focus groups, ran an employee survey, and met with a small group of workers who may face extra barriers to speaking up, but the draft only says it “consulted stakeholders regularly.”
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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
S4-2
within ESRS S4: Consumers and End-users
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Use the page’s plain-language explainer, then work through the step-by-step preparation section to identify the datapoints you need, the evidence pack, and the draft-output options. It is designed to help you assemble a practical first draft rather than to act as an official source.
The page lists the datapoints to prepare, including reporting routes, complaint route, access arrangements, complaint metrics, resolved case rate, reply timing, fixing approach, remedied matters, stakeholder contact methods, at-risk groups, and engagement approach. Use that list as your collection checklist.
The page is set up to help you decide what to include by walking through the preparation steps and the datapoints to prepare. It does not give a formal methodology, so use the page to structure your internal approach and document the choices you make.
The page is useful for assigning ownership because it separates preparation, evidence, and assurance readiness. In practice, you would use it to allocate each datapoint and evidence item to the relevant business owner, then confirm who reviews the final draft.
The page includes an evidence pack with five items and six assurance claims to verify, each framed around claim, risk, and evidence. Use those sections to assemble a pack that shows where the data came from and how it was checked.
The page lists common reporting gaps and mistakes, so it is intended to help you spot missing datapoints, weak evidence, or unclear drafting before sign-off. Use that section as a pre-submission quality check.
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is meant to support the preparation and assurance-readiness process. Use it alongside the page’s datapoints, assurance claims, and evidence pack to organise your draft.
The Download Centre also provides a printable Library Card in PDF format. It is there as a quick reference while you work through the page’s preparation steps, evidence pack, and draft-output section.
Yes. The page includes synthetic illustrative example disclosures, including a quantitative table, which you can use to see how the information might be presented in draft form.
The draft-output section gives visualisation ideas, narrative starters, and a content-index line to help you convert collected data into report-ready wording. Use those prompts to shape the narrative after you have completed the datapoints and evidence checks.
More questions this page can help with