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GRI Training Partner GRI 3 · Material Topics · Disclosure GRI 3-3

Management of material topics

GRI 3-3 · mandatory · narrative disclosure

Disclosure 3-3 requires an organization to explain how it manages each material topic reported under Disclosure 3-2. The requirements apply separately to every material topic. Where the same policy, process or action applies to several topics, the organization can report the information once and provide clear references identifying all topics covered.

Legal status

GRI 3: Material Topics 2021 is effective for reports or other materials published on or after 1 January 2023.

Disclosure focus

For each material topic, the organization must describe its actual and potential, negative and positive impacts on the economy, environment and people, including impacts on their human rights. A high-level overview is sufficient; an exhaustive list of every impact is not required.

The organization should distinguish actual from potential impacts and negative from positive impacts. It can also describe whether impacts are short- or long-term, whether negative impacts are systemic or incident-specific, and which economic resources, environmental resources, stakeholder categories and geographic locations are affected.

For negative impacts, the organization must report whether it is involved through its activities or as a result of its business relationships and describe those activities or relationships. Where possible, it should distinguish whether it causes or contributes to the impact through its activities or whether the impact is directly linked to its operations, products or services through a business relationship.

Where impacts relate to specific activities, the organization should identify the type and geographic location of those activities. Where they relate to business relationships, it should identify the relationship type, position in the value chain and geographic location.

The organization must describe topic-specific policies and commitments. It can cross-reference policy information already reported under GRI 2-23. Commitments should explain the organization’s intent and stance, whether they are based only on legal compliance or extend beyond compliance, and any relevant authoritative intergovernmental instruments.

The organization must describe actions to prevent or mitigate potential negative impacts, actions to address actual negative impacts — including provision of or cooperation in remediation — and actions to manage actual and potential positive impacts.

The action description should explain how impact findings are integrated into relevant functions and processes, which level and function are responsible, and how decision-making, budget allocation and oversight support the actions. It should also address actual impacts identified in previous reporting periods that continue to be managed.

For potential negative impacts, the organization can describe incident-specific and systemic preventive measures, its application of the precautionary principle, public information, scientific research, collaborative prevention efforts and the use or increase of leverage over business relationships. Where a relationship has been terminated because leverage was insufficient, the organization should explain whether it assessed potential negative impacts resulting from the termination itself.

For actual negative impacts, the organization should provide examples of specific remedies or types of remedy and explain how grievance mechanisms or other remediation processes reported under GRI 2-25 enabled remediation. Corrective action, investigation or disciplinary action should not be presented automatically as remedy unless the harm to affected stakeholders or resources was addressed.

For positive impacts, the organization should identify the beneficial change to the economy, environment or people rather than reporting only programmes, spending or outputs.

The organization must describe how it tracks the effectiveness of actions. Tracking methods can include audits, verification, impact assessments, measurement systems, stakeholder feedback, grievance mechanisms, ratings and benchmarking. The organization should demonstrate a credible link between specific actions and the effective management of impacts.

Goals and targets should explain how they were set, how they reflect sustainability context, whether they are informed by authoritative intergovernmental instruments or scientific consensus, whether they are mandatory or voluntary, which activities or business relationships they cover, the baseline and the timeline.

When reporting progress, the organization should state whether progress is satisfactory. Where a goal or target was not achieved, it should explain why. It should also provide examples of lessons learned and show how these lessons were incorporated into operational policies and procedures.

The organization must describe how stakeholder engagement informed the actions taken and the assessment of effectiveness. This can include affected stakeholders’ participation in determining appropriate remedy and the use of stakeholder feedback to assess whether actions have improved outcomes.

If a policy, action, target, tracking process or stakeholder-engagement process does not exist, the organization should report this fact directly. If the organization does not manage a material topic, it should explain why or describe plans to manage it.

Reasons for omission are permitted for GRI 3-3 where required information cannot be reported. They are not permitted for GRI 3-1 or GRI 3-2. The affected requirement, applicable reason and required explanation must be stated in the GRI content index.

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.

  • Actual and potential, negative and positive impacts

    Sustainability reporting

    Describe the impacts represented by the material topic on the economy, environment and people, including human rights.

    Evidence Topic impact register, impact assessment, affected-stakeholder evidence and geographic or value-chain mapping.

    Watch for The published response for actual and potential, negative and positive impacts is incomplete or does not match the supporting records.

  • Involvement in negative impacts

    Sustainability reporting

    For negative impacts, describe whether involvement arises through activities or business relationships and identify those activities or relationships.

    Evidence Cause-contribute-direct-link assessment, activity register, relationship map and impact evidence.

    Watch for The published response for involvement in negative impacts is incomplete or does not match the supporting records.

  • Policies and commitments

    Sustainability reporting

    Describe topic-specific policies and commitments and cross-reference GRI 2-23 where appropriate.

    Evidence Approved policies, commitments, legal review and authoritative-instrument mapping.

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

  • Prevention and mitigation of potential negative impacts

    Operations / Sustainability reporting

    Describe actions to prevent or mitigate potential negative impacts.

    Evidence Prevention controls, mitigation plans, due-diligence actions, budgets, responsibility matrix and oversight records.

    Watch for The published response for prevention and mitigation of potential negative impacts is incomplete or does not match the supporting records.

  • Response and remediation for actual negative impacts

    Operations / Sustainability reporting

    Describe actions to address actual negative impacts, including provision of or cooperation in remediation.

    Evidence Corrective-action and remedy records, grievance-mechanism files, affected-stakeholder evidence and closure review.

    Watch for The published response for response and remediation for actual negative impacts is incomplete or does not match the supporting records.

  • Management of positive impacts

    Operations / Sustainability reporting

    Describe actions that manage actual and potential positive impacts and the beneficial change they are intended to produce.

    Evidence Programme logic, impact evidence, beneficiary records and outcome monitoring.

    Watch for The published response for management of positive impacts is incomplete or does not match the supporting records.

  • Tracking effectiveness

    Sustainability reporting

    Describe the processes used to track whether actions effectively manage the impacts.

    Evidence Monitoring framework, audits, impact assessments, verification, grievance data, stakeholder feedback and benchmarking.

    Watch for The published response for tracking effectiveness is incomplete or does not match the supporting records.

  • Goals, targets and indicators

    Sustainability reporting

    Report the goals, targets and indicators used to evaluate progress, including scope, baseline, timeline and mandatory or voluntary status.

    Evidence Approved target register, methodology, baseline, indicator definitions, scientific or policy basis and scope mapping.

    Watch for The published response for goals, targets and indicators is incomplete or does not match the supporting records.

  • Progress and effectiveness conclusions

    Sustainability reporting

    Report progress and state whether it is satisfactory; explain why a goal or target was not achieved.

    Evidence Performance results, target calculations, effectiveness review, variance analysis and management conclusion.

    Watch for The published response for progress and effectiveness conclusions is incomplete or does not match the supporting records.

  • Lessons learned

    Operations / Sustainability reporting

    Describe lessons learned and how they were incorporated into operational policies and procedures.

    Evidence Post-implementation reviews, incident lessons, procedure change log and approval evidence.

    Watch for The published response for lessons learned is incomplete or does not match the supporting records.

  • Stakeholder engagement on actions

    Stakeholder Engagement / Sustainability reporting

    Describe how engagement with affected stakeholders informed the actions taken.

    Evidence Engagement plans, participant and representation records, feedback and decision trail.

    Watch for The published response for stakeholder engagement on actions is incomplete or does not match the supporting records.

  • Stakeholder engagement on effectiveness

    Stakeholder Engagement / Sustainability reporting

    Describe how stakeholder views informed assessment of the effectiveness of actions.

    Evidence Outcome feedback, grievance evidence, remedy satisfaction records and effectiveness review.

    Watch for The published response for stakeholder engagement on effectiveness is incomplete or does not match the supporting records.

Before you start

  • Apply every requirement separately to each material topic reported under GRI 3-2. Shared information can be reported once only with clear references to every topic covered.
  • Report a missing policy, action, target, tracking process or stakeholder-engagement process directly. If a material topic is not managed, explain why or describe the plan to manage it.
  • Have the supporting records and the final response been reconciled?
+ Show GRI 3-3 sub-elements (LRA working checklist)

How to prepare it

Apply every requirement separately to each material topic reported under GRI 3-2. Shared information can be reported once only with clear references to every topic covered.
Collect and reconcile the records for: Actual and potential, negative and positive impacts; Involvement in negative impacts; Policies and commitments; Prevention and mitigation of potential negative impacts; Response and remediation for actual negative impacts; Management of positive impacts; Tracking effectiveness; Goals, targets and indicators; Progress and effectiveness conclusions; Lessons learned; Stakeholder engagement on actions; Stakeholder engagement on effectiveness.
Report a missing policy, action, target, tracking process or stakeholder-engagement process directly. If a material topic is not managed, explain why or describe the plan to manage it.
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.

For each material topic, provide the impact and involvement assessment, policies and commitments, prevention, mitigation and remediation actions, positive-impact actions, responsibility and budget evidence, tracking methods, goals, targets, progress, lessons learned and stakeholder-engagement records.

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

Better request

For each material topic, provide the impact and involvement assessment, policies and commitments, prevention, mitigation and remediation actions, positive-impact actions, responsibility and budget evidence, tracking methods, goals, targets, progress, lessons learned and stakeholder-engagement records.

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

Keep outputs and expenditure separate from impact outcomes. Corrective or disciplinary action is not automatically a remedy unless the harm to affected stakeholders or resources was addressed.

Context note

Describe continuing management of actual impacts identified in earlier periods and distinguish cause, contribution and direct linkage where possible.

Content index entry

Reasons for omission are permitted for GRI 3-3 where required information cannot be reported; identify the affected requirement, applicable reason and explanation.

Download Centre

Preparation tools & forms

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

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Check

For each claim, check the evidence

  • Actual and potential, negative and positive impacts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates actual and potential, negative and positive impacts.

    Evidence to check Topic impact register, impact assessment, affected-stakeholder evidence and geographic or value-chain mapping.

  • Involvement in negative impacts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates involvement in negative impacts.

    Evidence to check Cause-contribute-direct-link assessment, activity register, relationship map and impact evidence.

  • Policies and commitments is reported accurately and completely.

    Risk The response omits, misclassifies or overstates policies and commitments.

    Evidence to check Approved policies, commitments, legal review and authoritative-instrument mapping.

  • Prevention and mitigation of potential negative impacts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates prevention and mitigation of potential negative impacts.

    Evidence to check Prevention controls, mitigation plans, due-diligence actions, budgets, responsibility matrix and oversight records.

  • Response and remediation for actual negative impacts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates response and remediation for actual negative impacts.

    Evidence to check Corrective-action and remedy records, grievance-mechanism files, affected-stakeholder evidence and closure review.

  • Management of positive impacts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates management of positive impacts.

    Evidence to check Programme logic, impact evidence, beneficiary records and outcome monitoring.

  • Tracking effectiveness is reported accurately and completely.

    Risk The response omits, misclassifies or overstates tracking effectiveness.

    Evidence to check Monitoring framework, audits, impact assessments, verification, grievance data, stakeholder feedback and benchmarking.

  • Goals, targets and indicators is reported accurately and completely.

    Risk The response omits, misclassifies or overstates goals, targets and indicators.

    Evidence to check Approved target register, methodology, baseline, indicator definitions, scientific or policy basis and scope mapping.

  • Progress and effectiveness conclusions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates progress and effectiveness conclusions.

    Evidence to check Performance results, target calculations, effectiveness review, variance analysis and management conclusion.

  • Lessons learned is reported accurately and completely.

    Risk The response omits, misclassifies or overstates lessons learned.

    Evidence to check Post-implementation reviews, incident lessons, procedure change log and approval evidence.

  • Stakeholder engagement on actions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates stakeholder engagement on actions.

    Evidence to check Engagement plans, participant and representation records, feedback and decision trail.

  • Stakeholder engagement on effectiveness is reported accurately and completely.

    Risk The response omits, misclassifies or overstates stakeholder engagement on effectiveness.

    Evidence to check Outcome feedback, grievance evidence, remedy satisfaction records and effectiveness review.

Evidence pack to prepare

Common reporting gaps

  • Using one generic management narrative for every material topic.
  • Listing programmes, spend or outputs without describing the impacts managed.
  • Calling corrective action or investigation a remedy without evidence that harm was addressed.
  • Reporting targets without scope, baseline, timeline or an effectiveness conclusion.
  • Omitting unsatisfactory progress, lessons learned or stakeholder input.
  • Treating business relationships as automatically outside the topic boundary.
✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

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