Disclosure focus
Policy commitments can be set out in a standalone policy or across several documents, such as a Code of Conduct, Human Rights Policy, Environmental Policy or Business Partner Code. The organization should describe the expectations, values, principles and norms of behaviour established by the commitments rather than only listing document titles.
The organization must identify the authoritative intergovernmental instruments referenced by its policy commitments. These should be distinguished from private standards, certifications and voluntary initiatives in which the organization participates.
The organization must report whether the policy commitments stipulate conducting due diligence. Due diligence is the process used to identify, prevent, mitigate and account for how the organization addresses its actual and potential negative impacts. Financial, legal, acquisition, KYC or supplier-screening procedures should not be presented as responsible-business-conduct due diligence unless they address this purpose.
The organization must report whether the policy commitments stipulate applying the precautionary principle. The official term “precautionary principle” should be used rather than general expressions such as “precautionary approach”, “cautious decision-making” or “risk-based thinking”.
The organization must report whether its policy commitments stipulate respecting human rights. It must also separately describe its specific policy commitment to respect human rights, including the internationally recognised human rights covered and the categories of stakeholders, including at-risk or vulnerable groups, to which the commitment gives particular attention.
Internationally recognised human rights include, at a minimum, the rights set out in the UN International Bill of Human Rights and the fundamental rights established in the ILO Declaration on Fundamental Principles and Rights at Work. If the commitment covers all internationally recognised human rights, a brief statement of this fact is sufficient. If it covers only selected rights, the organization must identify those rights and can explain the limitation.
The stakeholder categories and at-risk or vulnerable groups reported should be those given particular attention in the policy commitment itself. A stakeholder assessment or impact assessment can support the commitment but should not be used as a substitute for the policy wording.
For each policy commitment, the organization must provide a public link where the commitment is publicly available. Where it is not publicly available, the organization must explain the reason. An intranet or restricted portal is not a public source.
The organization must report the approval level of each policy commitment and whether it is the organization’s most senior level. The most senior level can be the highest governance body or the most senior executive, depending on the organization’s governance structure. Committee approval should not automatically be treated as approval at the most senior level.
The organization must report the extent to which each commitment applies to its activities and business relationships. Where a commitment applies only to selected activities or relationship types, these should be identified. The organization should also explain whether business relationships are obligated to comply with the commitments or are only encouraged to align with them.
The organization must describe how the commitments are communicated to workers, business partners and other relevant parties. It can additionally explain whether the commitments must be read, agreed to or regularly signed, the communication channels used, and how barriers are removed through accessible formats and relevant languages.
Communication under Disclosure 2-23 should be distinguished from embedding and implementation under Disclosure 2-24. Allocation of responsibility, integration into operational procedures, implementation through business relationships and implementation training are reported primarily under Disclosure 2-24.
If a policy commitment or practice does not exist, the organization should report this fact directly. Reasons for omission are permitted for Disclosure 2-23 where required information exists but cannot be reported. In that case, the affected requirement, applicable reason and required explanation must be provided in the GRI content index.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI 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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Policy commitments and their content
Legal / ComplianceDescribe the expectations, values, principles and norms of behaviour established by the responsible-business-conduct policy commitments.
Evidence Dated source records, governance papers and approval evidence supporting policy commitments and their content.
Watch for The published response for policy commitments and their content is incomplete or does not match the supporting records.
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Authoritative intergovernmental instruments
Legal / ComplianceIdentify the authoritative intergovernmental instruments referenced by the commitments and distinguish them from private initiatives.
Evidence Dated source records, governance papers and approval evidence supporting authoritative intergovernmental instruments.
Watch for The published response for authoritative intergovernmental instruments is incomplete or does not match the supporting records.
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Due-diligence commitment
Legal / ComplianceState whether the commitments stipulate conducting due diligence for actual and potential negative impacts.
Evidence Dated source records, governance papers and approval evidence supporting due-diligence commitment.
Watch for The published response for due-diligence commitment is incomplete or does not match the supporting records.
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Precautionary-principle commitment
Legal / ComplianceState whether the commitments stipulate applying the precautionary principle.
Evidence Dated source records, governance papers and approval evidence supporting precautionary-principle commitment.
Watch for The published response for precautionary-principle commitment is incomplete or does not match the supporting records.
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Specific commitment to respect human rights
Legal / ComplianceDescribe the organisation's specific policy commitment to respect human rights.
Evidence Dated source records, governance papers and approval evidence supporting specific commitment to respect human rights.
Watch for The published response for specific commitment to respect human rights is incomplete or does not match the supporting records.
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Rights and stakeholder groups receiving attention
Legal / ComplianceIdentify the internationally recognised human rights covered and stakeholder categories, including at-risk or vulnerable groups, receiving particular attention.
Evidence Dated source records, governance papers and approval evidence supporting rights and stakeholder groups receiving attention.
Watch for The published response for rights and stakeholder groups receiving attention is incomplete or does not match the supporting records.
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Public policy link
Legal / ComplianceProvide a public link for each policy commitment that is publicly available.
Evidence Dated source records, governance papers and approval evidence supporting public policy link.
Watch for The published response for public policy link is incomplete or does not match the supporting records.
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Reason a commitment is not public
Legal / ComplianceExplain why a policy commitment is not publicly available where applicable.
Evidence Dated source records, governance papers and approval evidence supporting reason a commitment is not public.
Watch for The published response for reason a commitment is not public is incomplete or does not match the supporting records.
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Approval level
Legal / ComplianceReport the approval level of each commitment and whether it is the organisation's most senior level.
Evidence Dated source records, governance papers and approval evidence supporting approval level.
Watch for The published response for approval level is incomplete or does not match the supporting records.
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Application scope
Legal / ComplianceReport the extent to which each commitment applies to activities and business relationships.
Evidence Dated source records, governance papers and approval evidence supporting application scope.
Watch for The published response for application scope is incomplete or does not match the supporting records.
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Communication
Legal / ComplianceDescribe how commitments are communicated to workers, business partners and other relevant parties.
Evidence Dated source records, governance papers and approval evidence supporting communication.
Watch for The published response for communication is incomplete or does not match the supporting records.
Before you start
- Compile the complete policy inventory for responsible business conduct; do not limit it to material topics or material impacts, risks and opportunities.
- Keep communication under GRI 2-23 separate from embedding and implementation under GRI 2-24.
- Have the supporting records and the final response been reconciled?
How to prepare it
Request the data
Request the disclosure evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Provide the complete policy register and texts, instrument references, due-diligence and precautionary-principle wording, human-rights scope, public links, approval records, application mapping and communication evidence.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
Provide the complete policy register and texts, instrument references, due-diligence and precautionary-principle wording, human-rights scope, public links, approval records, application mapping and communication evidence.
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
Preserve the defined terms due diligence, precautionary principle and internationally recognised human rights, and distinguish public instruments from private standards.
Context note
State directly where a policy commitment or practice does not exist, or where a commitment is not publicly available.
Download Centre
Preparation tools & forms
Download preparation tools for GRI 2-23 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
Policy commitments and their content is reported accurately and completely.
Risk The response omits, misclassifies or overstates policy commitments and their content.
Evidence to check Dated source records, governance papers and approval evidence supporting policy commitments and their content.
Authoritative intergovernmental instruments is reported accurately and completely.
Risk The response omits, misclassifies or overstates authoritative intergovernmental instruments.
Evidence to check Dated source records, governance papers and approval evidence supporting authoritative intergovernmental instruments.
Due-diligence commitment is reported accurately and completely.
Risk The response omits, misclassifies or overstates due-diligence commitment.
Evidence to check Dated source records, governance papers and approval evidence supporting due-diligence commitment.
Precautionary-principle commitment is reported accurately and completely.
Risk The response omits, misclassifies or overstates precautionary-principle commitment.
Evidence to check Dated source records, governance papers and approval evidence supporting precautionary-principle commitment.
Specific commitment to respect human rights is reported accurately and completely.
Risk The response omits, misclassifies or overstates specific commitment to respect human rights.
Evidence to check Dated source records, governance papers and approval evidence supporting specific commitment to respect human rights.
Rights and stakeholder groups receiving attention is reported accurately and completely.
Risk The response omits, misclassifies or overstates rights and stakeholder groups receiving attention.
Evidence to check Dated source records, governance papers and approval evidence supporting rights and stakeholder groups receiving attention.
Public policy link is reported accurately and completely.
Risk The response omits, misclassifies or overstates public policy link.
Evidence to check Dated source records, governance papers and approval evidence supporting public policy link.
Reason a commitment is not public is reported accurately and completely.
Risk The response omits, misclassifies or overstates reason a commitment is not public.
Evidence to check Dated source records, governance papers and approval evidence supporting reason a commitment is not public.
Approval level is reported accurately and completely.
Risk The response omits, misclassifies or overstates approval level.
Evidence to check Dated source records, governance papers and approval evidence supporting approval level.
Application scope is reported accurately and completely.
Risk The response omits, misclassifies or overstates application scope.
Evidence to check Dated source records, governance papers and approval evidence supporting application scope.
Communication is reported accurately and completely.
Risk The response omits, misclassifies or overstates communication.
Evidence to check Dated source records, governance papers and approval evidence supporting communication.
Evidence pack to prepare
Common reporting gaps
- Listing policy titles without describing their commitments.
- Presenting private standards as authoritative intergovernmental instruments.
- Using generic risk or transaction checks as responsible-business-conduct due diligence.
- Replacing precautionary principle with precautionary approach.
- Omitting public availability, approval, application or communication for individual commitments.
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Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 2-23
within GRI 2: General Disclosures
Guides that settle this question
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