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Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
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GRI 205: Anti-corruption·Disclosure GRI 205-3
Confirmed incidents of corruption and actions taken
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official Global Reporting Initiative source.
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.
Published passport
Last reviewed 2026-08-01
Reviewed by
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
LRA educational guidance · Not issued or endorsed by Global Reporting Initiative
Standard
GRI 205: Anti-corruption
Disclosure GRI 205-3 · 2016
Last reviewed
2026-08-01
LRA educational guidance · Not issued or endorsed by Global Reporting Initiative
To prepare this disclosure
Disclosure focus
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.
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.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Definition of corruption | Required methodological control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting definition of corruption. | Legal / Compliance / Sustainability Reporting |
| Confirmed-incident criterion | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting confirmed-incident criterion. | Legal / Compliance / Sustainability Reporting |
| Total confirmed incidents | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting total confirmed incidents. | Legal / Compliance / Sustainability Reporting |
| Nature of confirmed incidents | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting nature of confirmed incidents. | Legal / Compliance / Sustainability Reporting |
| Incidents involving employee dismissal or discipline | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting incidents involving employee dismissal or discipline. | Legal / Compliance / Sustainability Reporting |
| Number of employees affected | Additional information only. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting number of employees affected. | People / Compliance / Sustainability Reporting |
| Incidents involving partner-contract termination or non-renewal | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting incidents involving partner-contract termination or non-renewal. | Legal / Compliance / Sustainability Reporting |
| Number of contracts affected | Additional information only. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting number of contracts affected. | Sustainability Reporting / data owner |
| Business partner type | Necessary contextual information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting business partner type. | Sustainability Reporting / data owner |
| Public legal cases brought during reporting period | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting public legal cases brought during reporting period. | Legal / Compliance / Sustainability Reporting |
| Organization or employee named as respondent | Required control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting organization or employee named as respondent. | People / Compliance / Sustainability Reporting |
| Public investigation, prosecution or closed case | Required scope control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting public investigation, prosecution or closed case. | Legal / Compliance / Sustainability Reporting |
| Legal case outcome or current status | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting legal case outcome or current status. | Legal / Compliance / Sustainability Reporting |
| Date substantiated | Required period control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting date substantiated. | Sustainability Reporting / data owner |
| Open investigations excluded | Required control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting open investigations excluded. | Sustainability Reporting / data owner |
| Incident overlap between sub-elements | Required reconciliation. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting incident overlap between sub-elements. | Legal / Compliance / Sustainability Reporting |
| Exact integer counts | Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting exact integer counts. | Sustainability Reporting / data owner |
| Estimates and rounding | Not appropriate. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting estimates and rounding. | Sustainability Reporting / data owner |
| Contractors separated from employees | Required classification control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting contractors separated from employees. | People / Compliance / Sustainability Reporting |
| Reporting boundary aligned with GRI 2-2 | Required contextual information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting reporting boundary aligned with gri 2-2. | Sustainability Reporting / data owner |
| Confidentiality assessment | Required where applicable. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus. | Approved source records, calculation files, reconciliations and review evidence supporting confidentiality assessment. | Sustainability Reporting / data owner |
| Reason for omission | 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. | Approved source records, calculation files, reconciliations and review evidence supporting reason for omission. | Sustainability Reporting / data owner |
＋ Show GRI 205-3 sub-elements (LRA working checklist)
Required methodological control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Additional information only. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Additional information only. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Necessary contextual information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required scope control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required period control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required reconciliation. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Not appropriate. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required classification control. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required contextual information. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
Required where applicable. Capture and reconcile this item using the scope, defined terms and calculation basis in the reviewed Disclosure focus.
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.
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.
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| Definition of corruption is reported accurately and completely. | The response omits, misclassifies or overstates definition of corruption. | Approved source records, calculation files, reconciliations and review evidence supporting definition of corruption. |
| Confirmed-incident criterion is reported accurately and completely. | The response omits, misclassifies or overstates confirmed-incident criterion. | Approved source records, calculation files, reconciliations and review evidence supporting confirmed-incident criterion. |
| Total confirmed incidents is reported accurately and completely. | The response omits, misclassifies or overstates total confirmed incidents. | Approved source records, calculation files, reconciliations and review evidence supporting total confirmed incidents. |
| Nature of confirmed incidents is reported accurately and completely. | The response omits, misclassifies or overstates nature of confirmed incidents. | 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. | The response omits, misclassifies or overstates incidents involving employee dismissal or discipline. | 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. | The response omits, misclassifies or overstates number of employees affected. | 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. | The response omits, misclassifies or overstates incidents involving partner-contract termination or non-renewal. | 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. | The response omits, misclassifies or overstates number of contracts affected. | Approved source records, calculation files, reconciliations and review evidence supporting number of contracts affected. |
| Business partner type is reported accurately and completely. | The response omits, misclassifies or overstates business partner type. | 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. | The response omits, misclassifies or overstates public legal cases brought during reporting period. | 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. | The response omits, misclassifies or overstates organization or employee named as respondent. | 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. | The response omits, misclassifies or overstates public investigation, prosecution or closed case. | 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. | The response omits, misclassifies or overstates legal case outcome or current status. | Approved source records, calculation files, reconciliations and review evidence supporting legal case outcome or current status. |
| Date substantiated is reported accurately and completely. | The response omits, misclassifies or overstates date substantiated. | Approved source records, calculation files, reconciliations and review evidence supporting date substantiated. |
| Open investigations excluded is reported accurately and completely. | The response omits, misclassifies or overstates open investigations excluded. | Approved source records, calculation files, reconciliations and review evidence supporting open investigations excluded. |
| Incident overlap between sub-elements is reported accurately and completely. | The response omits, misclassifies or overstates incident overlap between sub-elements. | Approved source records, calculation files, reconciliations and review evidence supporting incident overlap between sub-elements. |
| Exact integer counts is reported accurately and completely. | The response omits, misclassifies or overstates exact integer counts. | Approved source records, calculation files, reconciliations and review evidence supporting exact integer counts. |
| Estimates and rounding is reported accurately and completely. | The response omits, misclassifies or overstates estimates and rounding. | Approved source records, calculation files, reconciliations and review evidence supporting estimates and rounding. |
| Contractors separated from employees is reported accurately and completely. | The response omits, misclassifies or overstates contractors separated from employees. | 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. | The response omits, misclassifies or overstates reporting boundary aligned with gri 2-2. | Approved source records, calculation files, reconciliations and review evidence supporting reporting boundary aligned with gri 2-2. |
| Confidentiality assessment is reported accurately and completely. | The response omits, misclassifies or overstates confidentiality assessment. | Approved source records, calculation files, reconciliations and review evidence supporting confidentiality assessment. |
| Reason for omission is reported accurately and completely. | The response omits, misclassifies or overstates reason for omission. | 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
Available framework references and nearby disclosures relevant to preparing this requirement.
GRI
GRI 205-3
within GRI 205: Anti-corruption
Related & explore
Operations assessed for risks related to corruption → CardCommunication and training about anti-corruption policies and procedures → Card
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