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GRI Training Partner GRI 205 · Anti-corruption · Disclosure GRI 205-3

Confirmed incidents of corruption and actions taken

GRI 205-3 · mandatory · metrics + narrative

Disclosure 205-3 requires an organization to report the total number and nature of confirmed incidents of corruption. A confirmed incident is an incident that has been substantiated. Cases that remain under investigation at the reporting cut-off are not confirmed incidents. An incident does not need to be fully closed in every disciplinary, contractual or legal respect once the corruption finding has been substantiated.

Legal status

GRI 205: Anti-corruption 2016 remains applicable at the date of this review. A revised Corruption Standard has been published only as an exposure draft and is not yet an applicable requirement.

Start preparing ↓ Official Global Reporting Initiative source ↗

Disclosure focus

The organization also reports the number of confirmed incidents in which employees were dismissed or disciplined and the number of confirmed incidents in which contracts with business partners were terminated or not renewed because of corruption-related violations. These figures count incidents, not employees, disciplinary measures or contracts.

A single confirmed incident can appear in the total incident count and in one or both action-related metrics. This is not duplicate counting because the sub-elements report different characteristics of the same incident. Duplicate counting should be prevented within each individual metric.

The organization also reports public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes or current status of those cases. Public legal cases can include ongoing public investigations, prosecutions and closed cases.

Business partners are not limited to suppliers and can include agents, intermediaries, joint-venture partners, governments, customers and clients. Employee-related figures should include only individuals in an employment relationship with the organization.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official Global Reporting Initiative source.

Prepare

What to collect before drafting

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

  • Definition of corruption

    Legal / Compliance / Sustainability Reporting

    Required methodological control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting definition of corruption.

    Watch for The published response for definition of corruption is incomplete or does not match the supporting records.

  • Confirmed-incident criterion

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting confirmed-incident criterion.

    Watch for The published response for confirmed-incident criterion is incomplete or does not match the supporting records.

  • Total confirmed incidents

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting total confirmed incidents.

    Watch for The published response for total confirmed incidents is incomplete or does not match the supporting records.

  • Nature of confirmed incidents

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting nature of confirmed incidents.

    Watch for The published response for nature of confirmed incidents is incomplete or does not match the supporting records.

  • Incidents involving employee dismissal or discipline

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting incidents involving employee dismissal or discipline.

    Watch for The published response for incidents involving employee dismissal or discipline is incomplete or does not match the supporting records.

  • Number of employees affected

    People / Compliance / Sustainability Reporting

    Additional information only. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting number of employees affected.

    Watch for The published response for number of employees affected is incomplete or does not match the supporting records.

  • Incidents involving partner-contract termination or non-renewal

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting incidents involving partner-contract termination or non-renewal.

    Watch for The published response for incidents involving partner-contract termination or non-renewal is incomplete or does not match the supporting records.

  • Number of contracts affected

    Sustainability Reporting / data owner

    Additional information only. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting number of contracts affected.

    Watch for The published response for number of contracts affected is incomplete or does not match the supporting records.

  • Business partner type

    Sustainability Reporting / data owner

    Necessary contextual information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting business partner type.

    Watch for The published response for business partner type is incomplete or does not match the supporting records.

  • Public legal cases brought during reporting period

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting public legal cases brought during reporting period.

    Watch for The published response for public legal cases brought during reporting period is incomplete or does not match the supporting records.

  • Organization or employee named as respondent

    People / Compliance / Sustainability Reporting

    Required control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting organization or employee named as respondent.

    Watch for The published response for organization or employee named as respondent is incomplete or does not match the supporting records.

  • Public investigation, prosecution or closed case

    Legal / Compliance / Sustainability Reporting

    Required scope control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting public investigation, prosecution or closed case.

    Watch for The published response for public investigation, prosecution or closed case is incomplete or does not match the supporting records.

  • Legal case outcome or current status

    Legal / Compliance / Sustainability Reporting

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting legal case outcome or current status.

    Watch for The published response for legal case outcome or current status is incomplete or does not match the supporting records.

  • Date substantiated

    Sustainability Reporting / data owner

    Required period control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting date substantiated.

    Watch for The published response for date substantiated is incomplete or does not match the supporting records.

  • Open investigations excluded

    Sustainability Reporting / data owner

    Required control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting open investigations excluded.

    Watch for The published response for open investigations excluded is incomplete or does not match the supporting records.

  • Incident overlap between sub-elements

    Legal / Compliance / Sustainability Reporting

    Required reconciliation. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting incident overlap between sub-elements.

    Watch for The published response for incident overlap between sub-elements is incomplete or does not match the supporting records.

  • Exact integer counts

    Sustainability Reporting / data owner

    Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting exact integer counts.

    Watch for The published response for exact integer counts is incomplete or does not match the supporting records.

  • Estimates and rounding

    Sustainability Reporting / data owner

    Not appropriate. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting estimates and rounding.

    Watch for The published response for estimates and rounding is incomplete or does not match the supporting records.

  • Contractors separated from employees

    People / Compliance / Sustainability Reporting

    Required classification control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting contractors separated from employees.

    Watch for The published response for contractors separated from employees is incomplete or does not match the supporting records.

  • Reporting boundary aligned with GRI 2-2

    Sustainability Reporting / data owner

    Required contextual information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting reporting boundary aligned with gri 2-2.

    Watch for The published response for reporting boundary aligned with gri 2-2 is incomplete or does not match the supporting records.

  • Confidentiality assessment

    Sustainability Reporting / data owner

    Required where applicable. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting confidentiality assessment.

    Watch for The published response for confidentiality assessment is incomplete or does not match the supporting records.

  • Reason for omission

    Sustainability Reporting / data owner

    Required in GRI content index where applicable. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files, reconciliations and review evidence supporting reason for omission.

    Watch for The published response for reason for omission is incomplete or does not match the supporting records.

Before you start

  • Disclosure 205-3 requires an organization to report the total number and nature of confirmed incidents of corruption. A confirmed incident is an incident that has been substantiated. Cases that remain under investigation at the reporting cut-off are not confirmed incidents. An incident does not need to be fully closed in every disciplinary, contractual or legal respect once the corruption finding has been substantiated.
  • Apply Disclosure 205-3 when the related topic is material and this disclosure is relevant to the organisation's impacts, or when an applicable GRI Sector Standard identifies it for reporting.
  • Have the supporting records and the final response been reconciled?
＋ Show GRI 205-3 sub-elements (LRA working checklist)

How to prepare it

Disclosure 205-3 requires an organization to report the total number and nature of confirmed incidents of corruption. A confirmed incident is an incident that has been substantiated. Cases that remain under investigation at the reporting cut-off are not confirmed incidents. An incident does not need to be fully closed in every disciplinary, contractual or legal respect once the corruption finding has been substantiated.
Collect and reconcile the records for: Definition of corruption; Confirmed-incident criterion; Total confirmed incidents; Nature of confirmed incidents; Incidents involving employee dismissal or discipline; Number of employees affected; Incidents involving partner-contract termination or non-renewal; Number of contracts affected; Business partner type; Public legal cases brought during reporting period; Organization or employee named as respondent; Public investigation, prosecution or closed case; Legal case outcome or current status; Date substantiated; Open investigations excluded; Incident overlap between sub-elements; Exact integer counts; Estimates and rounding; Contractors separated from employees; Reporting boundary aligned with GRI 2-2; Confidentiality assessment; Reason for omission.
Apply Disclosure 205-3 when the related topic is material and this disclosure is relevant to the organisation's impacts, or when an applicable GRI Sector Standard identifies it for reporting.
Draft the response using the defined terms shown in the disclosure focus; do not substitute broader internal labels.
Review the final wording against every requirement and the supporting governance or data records before sign-off.

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 reporting-period records and reconciliations for Disclosure 205-3: Definition of corruption; Confirmed-incident criterion; Total confirmed incidents; Nature of confirmed incidents; Incidents involving employee dismissal or discipline; Number of employees affected; Incidents involving partner-contract termination or non-renewal; Number of contracts affected; Business partner type; Public legal cases brought during reporting period; Organization or employee named as respondent; Public investigation, prosecution or closed case; Legal case outcome or current status; Date substantiated; Open investigations excluded; Incident overlap between sub-elements; Exact integer counts; Estimates and rounding; Contractors separated from employees; Reporting boundary aligned with GRI 2-2; Confidentiality assessment; Reason for omission. Include scope, definitions, methods, assumptions, limitations, owners and approvals.

Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.

Better request

Provide the reporting-period records and reconciliations for Disclosure 205-3: Definition of corruption; Confirmed-incident criterion; Total confirmed incidents; Nature of confirmed incidents; Incidents involving employee dismissal or discipline; Number of employees affected; Incidents involving partner-contract termination or non-renewal; Number of contracts affected; Business partner type; Public legal cases brought during reporting period; Organization or employee named as respondent; Public investigation, prosecution or closed case; Legal case outcome or current status; Date substantiated; Open investigations excluded; Incident overlap between sub-elements; Exact integer counts; Estimates and rounding; Contractors separated from employees; Reporting boundary aligned with GRI 2-2; Confidentiality assessment; Reason for omission. Include scope, definitions, methods, assumptions, limitations, owners and approvals.

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

Business partners are not limited to suppliers and can include agents, intermediaries, joint-venture partners, governments, customers and clients. Employee-related figures should include only individuals in an employment relationship with the organization.

Context note

Keep mandatory Requirements, GRI recommendations and additional LRA preparation controls clearly distinguished. Use a GRI 1 reason for omission where an applicable requirement cannot be reported.

Download Centre

Preparation tools & forms

Download preparation tools for GRI 205-3 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Check

For each claim, check the evidence

  • Definition of corruption is reported accurately and completely.

    Risk The response omits, misclassifies or overstates definition of corruption.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting definition of corruption.

  • Confirmed-incident criterion is reported accurately and completely.

    Risk The response omits, misclassifies or overstates confirmed-incident criterion.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting confirmed-incident criterion.

  • Total confirmed incidents is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total confirmed incidents.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting total confirmed incidents.

  • Nature of confirmed incidents is reported accurately and completely.

    Risk The response omits, misclassifies or overstates nature of confirmed incidents.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting nature of confirmed incidents.

  • Incidents involving employee dismissal or discipline is reported accurately and completely.

    Risk The response omits, misclassifies or overstates incidents involving employee dismissal or discipline.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting incidents involving employee dismissal or discipline.

  • Number of employees affected is reported accurately and completely.

    Risk The response omits, misclassifies or overstates number of employees affected.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting number of employees affected.

  • Incidents involving partner-contract termination or non-renewal is reported accurately and completely.

    Risk The response omits, misclassifies or overstates incidents involving partner-contract termination or non-renewal.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting incidents involving partner-contract termination or non-renewal.

  • Number of contracts affected is reported accurately and completely.

    Risk The response omits, misclassifies or overstates number of contracts affected.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting number of contracts affected.

  • Business partner type is reported accurately and completely.

    Risk The response omits, misclassifies or overstates business partner type.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting business partner type.

  • Public legal cases brought during reporting period is reported accurately and completely.

    Risk The response omits, misclassifies or overstates public legal cases brought during reporting period.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting public legal cases brought during reporting period.

  • Organization or employee named as respondent is reported accurately and completely.

    Risk The response omits, misclassifies or overstates organization or employee named as respondent.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting organization or employee named as respondent.

  • Public investigation, prosecution or closed case is reported accurately and completely.

    Risk The response omits, misclassifies or overstates public investigation, prosecution or closed case.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting public investigation, prosecution or closed case.

  • Legal case outcome or current status is reported accurately and completely.

    Risk The response omits, misclassifies or overstates legal case outcome or current status.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting legal case outcome or current status.

  • Date substantiated is reported accurately and completely.

    Risk The response omits, misclassifies or overstates date substantiated.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting date substantiated.

  • Open investigations excluded is reported accurately and completely.

    Risk The response omits, misclassifies or overstates open investigations excluded.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting open investigations excluded.

  • Incident overlap between sub-elements is reported accurately and completely.

    Risk The response omits, misclassifies or overstates incident overlap between sub-elements.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting incident overlap between sub-elements.

  • Exact integer counts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates exact integer counts.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting exact integer counts.

  • Estimates and rounding is reported accurately and completely.

    Risk The response omits, misclassifies or overstates estimates and rounding.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting estimates and rounding.

  • Contractors separated from employees is reported accurately and completely.

    Risk The response omits, misclassifies or overstates contractors separated from employees.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting contractors separated from employees.

  • Reporting boundary aligned with GRI 2-2 is reported accurately and completely.

    Risk The response omits, misclassifies or overstates reporting boundary aligned with gri 2-2.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting reporting boundary aligned with gri 2-2.

  • Confidentiality assessment is reported accurately and completely.

    Risk The response omits, misclassifies or overstates confidentiality assessment.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting confidentiality assessment.

  • Reason for omission is reported accurately and completely.

    Risk The response omits, misclassifies or overstates reason for omission.

    Evidence to check Approved source records, calculation files, reconciliations and review evidence supporting reason for omission.

Evidence pack to prepare

Common reporting gaps

  • Counting allegations or open investigations as confirmed incidents.
  • Counting employees, measures or contracts instead of incidents in the action metrics.
  • Using internal labels in place of the defined GRI terms.
  • Leaving a required preparation field unsupported by traceable evidence.
  • Treating GRI recommendations as mandatory requirements or mandatory requirements as optional.
  • Publishing estimates, exclusions or partial scope without methods, assumptions and the applicable reason for omission.
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Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 205-3

within GRI 205: Anti-corruption

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