Disclosure focus
The disclosure must explain four elements for each policy commitment:
1. how responsibility for implementation is allocated across different levels within the organization;2. how the commitment is integrated into organizational strategies, operational policies and operational procedures;3. how the commitment is implemented with and through business relationships;4. the training provided on implementing the commitment.
The analysis should begin with the complete inventory of policy commitments reported under Disclosure 2-23. The organization should not select only those commitments for which implementation is most developed. Where several commitments use the same embedding arrangements, the organization can describe the common process and identify the commitments to which it applies.
For responsibility allocation, the organization can describe the most senior level with oversight of or accountability for implementation, the functions with day-to-day responsibility, their reporting lines and the reasons responsibility is assigned to them. It can also explain whether responsible business conduct is formally discussed by the highest governance body or senior executives and whether cross-functional or cross-level discussion mechanisms exist.
Oversight, accountability and day-to-day responsibility should be distinguished. The term “Board” should be used only where the Board is the organization’s highest governance body, and the official term “senior executives” should not be replaced automatically by broader internal categories such as senior leaders.
For integration, the organization should describe how policy commitments are aligned with risk-management systems, management policies, economic, environmental, social and human rights impact assessments, due diligence processes and financial or other performance incentives.
The organization should also explain how the commitments are applied when making decisions, such as decisions about sourcing, investment, operating locations, products, customers or projects, and the systems used to monitor compliance throughout activities and business relationships.
For implementation with and through business relationships, the organization can describe procurement and investment policies and practices, pre-qualification and screening criteria, bidding requirements, contracts, investment agreements, supplier codes and the use of commitments when deciding whether to initiate, continue, suspend or terminate a relationship.
The disclosure can also explain how the organization enables or supports business partners and other parties through capacity building, peer sharing or corrective-action support, and any incentives offered for implementation, such as price premiums, increased orders or long-term contracts.
For training, the organization should describe the content, audience, mandatory status, form and frequency of the training and any methods used to assess effectiveness. It should explain whether training covers general implementation or specific situations and whether it is provided to workers, persons with day-to-day responsibility, persons with oversight or accountability, business partners and other relevant parties.
Numbers or percentages of workers, business partners or other parties trained are optional additional information. Where such metrics are reported, the eligible population, denominator, overlapping groups and reporting-period basis should be defined clearly.
The disclosure should report actual implementation. Where a commitment has not yet been embedded in a particular activity, function, geography or relationship type, the organization should state this directly rather than narrowing the reporting boundary or implying full implementation.
If a required policy, practice or process does not exist, the organization can comply by reporting this fact. Reasons for omission are permitted for Disclosure 2-24 where required information 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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Allocation of implementation responsibility
Sustainability reporting / StrategyDescribe how responsibility for implementing each policy commitment is allocated across organisational levels.
Evidence Dated source records, governance papers and approval evidence supporting allocation of implementation responsibility.
Watch for The published response for allocation of implementation responsibility is incomplete or does not match the supporting records.
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Integration into strategies, policies and procedures
Sustainability reporting / StrategyDescribe how each commitment is integrated into organisational strategies, operational policies, operational procedures and decision-making.
Evidence Dated source records, governance papers and approval evidence supporting integration into strategies, policies and procedures.
Watch for The published response for integration into strategies, policies and procedures is incomplete or does not match the supporting records.
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Implementation with and through business relationships
Sustainability reporting / StrategyDescribe how each commitment is implemented with and through business relationships.
Evidence Dated source records, governance papers and approval evidence supporting implementation with and through business relationships.
Watch for The published response for implementation with and through business relationships is incomplete or does not match the supporting records.
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Implementation training
Sustainability reporting / StrategyDescribe the training provided on implementing each commitment, including content, audience, mandatory status, form and frequency.
Evidence Dated source records, governance papers and approval evidence supporting implementation training.
Watch for The published response for implementation training is incomplete or does not match the supporting records.
Before you start
- Start with the complete inventory of policy commitments reported under GRI 2-23 and identify which shared embedding arrangements apply to which commitments.
- State actual implementation gaps directly rather than narrowing the reporting boundary or implying full implementation.
- 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.
For every GRI 2-23 commitment, provide responsibility matrices, strategy and procedure integration, business-relationship implementation records and training design and delivery evidence.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
For every GRI 2-23 commitment, provide responsibility matrices, strategy and procedure integration, business-relationship implementation records and training design and delivery 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
Distinguish oversight, accountability and day-to-day responsibility and keep optional training metrics separate from the required implementation description.
Context note
Explain common embedding arrangements once where appropriate and map them clearly to the affected commitments.
Download Centre
Preparation tools & forms
Download preparation tools for GRI 2-24 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
Allocation of implementation responsibility is reported accurately and completely.
Risk The response omits, misclassifies or overstates allocation of implementation responsibility.
Evidence to check Dated source records, governance papers and approval evidence supporting allocation of implementation responsibility.
Integration into strategies, policies and procedures is reported accurately and completely.
Risk The response omits, misclassifies or overstates integration into strategies, policies and procedures.
Evidence to check Dated source records, governance papers and approval evidence supporting integration into strategies, policies and procedures.
Implementation with and through business relationships is reported accurately and completely.
Risk The response omits, misclassifies or overstates implementation with and through business relationships.
Evidence to check Dated source records, governance papers and approval evidence supporting implementation with and through business relationships.
Implementation training is reported accurately and completely.
Risk The response omits, misclassifies or overstates implementation training.
Evidence to check Dated source records, governance papers and approval evidence supporting implementation training.
Evidence pack to prepare
Common reporting gaps
- Selecting only commitments with mature implementation.
- Confusing oversight, accountability and day-to-day responsibility.
- Describing policies without showing operational integration.
- Omitting implementation through business relationships.
- Reporting training participation metrics without explaining the training and embedding process.
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Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 2-24
within GRI 2: General Disclosures
Guides that settle this question
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