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GRI Training Partner GRI 403 · Occupational Health and Safety · Disclosure GRI 403-1

Occupational health and safety management system

GRI 403-1 · mandatory · narrative disclosure

Disclosure 403-1 requires an organisation to state whether it has implemented an occupational health and safety management system. An occupational health and safety management system is a set of interrelated or interacting elements used to establish an occupational health and safety policy and objectives and to achieve those objectives.

Legal status

GRI 403: Occupational Health and Safety 2018 remains applicable and is effective for reports or other materials published on or after 1 January 2021.

Disclosure focus

The organisation must state whether the system was implemented because of legal requirements and, if so, list those requirements. It must also state whether the system was implemented based on recognised risk management and/or management system standards or guidelines and, if so, list them. The organisation must describe the workers, activities and workplaces covered by the system and explain why any workers, activities or workplaces are not covered.

The organisation should determine and disclose the actual scope of the system. The disclosure does not permit the organisation to omit categories without explanation. It must identify all workers, activities and workplaces covered and explain every category that is not covered.

Relationship with GRI 403-8: Disclosure 403-1 describes whether an occupational health and safety management system has been implemented, the basis on which it was implemented, and the workers, activities and workplaces within its scope. Quantitative information on the number and percentage of workers covered by the system is reported separately under Disclosure 403-8.

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.

  • OHS management system implemented

    Occupational Health and Safety / People / Sustainability Reporting

    Prepare and reconcile this field using the definitions and scope in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files and review evidence supporting ohs management system implemented.

    Watch for The published response for ohs management system implemented is incomplete or does not match the supporting records.

  • Legal basis and listed requirements

    Occupational Health and Safety / People / Sustainability Reporting

    Prepare and reconcile this field using the definitions and scope in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files and review evidence supporting legal basis and listed requirements.

    Watch for The published response for legal basis and listed requirements is incomplete or does not match the supporting records.

  • Recognised standards or guidelines

    Occupational Health and Safety / People / Sustainability Reporting

    Prepare and reconcile this field using the definitions and scope in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files and review evidence supporting recognised standards or guidelines.

    Watch for The published response for recognised standards or guidelines is incomplete or does not match the supporting records.

  • Workers, activities and workplaces covered

    Occupational Health and Safety / People / Sustainability Reporting

    Prepare and reconcile this field using the definitions and scope in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files and review evidence supporting workers, activities and workplaces covered.

    Watch for The published response for workers, activities and workplaces covered is incomplete or does not match the supporting records.

  • Exclusions and reasons

    Occupational Health and Safety / People / Sustainability Reporting

    Prepare and reconcile this field using the definitions and scope in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files and review evidence supporting exclusions and reasons.

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

  • Relationship with GRI 403-8

    Occupational Health and Safety / People / Sustainability Reporting

    Prepare and reconcile this field using the definitions and scope in the reviewed Disclosure focus.

    Evidence Approved source records, calculation files and review evidence supporting relationship with gri 403-8.

    Watch for The published response for relationship with gri 403-8 is incomplete or does not match the supporting records.

Before you start

  • Disclosure 403-1 requires an organisation to state whether it has implemented an occupational health and safety management system. An occupational health and safety management system is a set of interrelated or interacting elements used to establish an occupational health and safety policy and objectives and to achieve those objectives.
  • Apply Disclosure 403-1 when the related topic is material and the disclosure is applicable under the relevant GRI Standard.
  • Have the supporting records and the final response been reconciled?
+ Show GRI 403-1 sub-elements (LRA working checklist)

How to prepare it

Disclosure 403-1 requires an organisation to state whether it has implemented an occupational health and safety management system. An occupational health and safety management system is a set of interrelated or interacting elements used to establish an occupational health and safety policy and objectives and to achieve those objectives.
Collect and reconcile the records for: OHS management system implemented; Legal basis and listed requirements; Recognised standards or guidelines; Workers, activities and workplaces covered; Exclusions and reasons; Relationship with GRI 403-8.
Apply Disclosure 403-1 when the related topic is material and the disclosure is applicable under the relevant GRI Standard.
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 403-1: OHS management system implemented; Legal basis and listed requirements; Recognised standards or guidelines; Workers, activities and workplaces covered; Exclusions and reasons; Relationship with GRI 403-8. 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 403-1: OHS management system implemented; Legal basis and listed requirements; Recognised standards or guidelines; Workers, activities and workplaces covered; Exclusions and reasons; Relationship with GRI 403-8. 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

Relationship with GRI 403-8: Disclosure 403-1 describes whether an occupational health and safety management system has been implemented, the basis on which it was implemented, and the workers, activities and workplaces within its scope. Quantitative information on the number and percentage of workers covered by the system is reported separately under Disclosure 403-8.

Context note

Keep mandatory GRI Requirements, GRI recommendations and additional LRA preparation controls clearly distinguished. Apply a GRI 1 reason for omission where required information cannot be reported.

Download Centre

Preparation tools & forms

Download preparation tools for GRI 403-1 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access

Check

For each claim, check the evidence

  • OHS management system implemented is reported accurately and completely.

    Risk The response omits, misclassifies or overstates ohs management system implemented.

    Evidence to check Approved source records, calculation files and review evidence supporting ohs management system implemented.

  • Legal basis and listed requirements is reported accurately and completely.

    Risk The response omits, misclassifies or overstates legal basis and listed requirements.

    Evidence to check Approved source records, calculation files and review evidence supporting legal basis and listed requirements.

  • Recognised standards or guidelines is reported accurately and completely.

    Risk The response omits, misclassifies or overstates recognised standards or guidelines.

    Evidence to check Approved source records, calculation files and review evidence supporting recognised standards or guidelines.

  • Workers, activities and workplaces covered is reported accurately and completely.

    Risk The response omits, misclassifies or overstates workers, activities and workplaces covered.

    Evidence to check Approved source records, calculation files and review evidence supporting workers, activities and workplaces covered.

  • Exclusions and reasons is reported accurately and completely.

    Risk The response omits, misclassifies or overstates exclusions and reasons.

    Evidence to check Approved source records, calculation files and review evidence supporting exclusions and reasons.

  • Relationship with GRI 403-8 is reported accurately and completely.

    Risk The response omits, misclassifies or overstates relationship with gri 403-8.

    Evidence to check Approved source records, calculation files and review evidence supporting relationship with gri 403-8.

Evidence pack to prepare

Common reporting gaps

  • Using internal or approximate wording in place of the defined GRI terms.
  • Changing the required reporting population or denominator without explanation.
  • Treating GRI recommendations or LRA preparation controls as mandatory disclosure requirements.
  • Leaving a reported field unsupported by traceable source evidence and review records.
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Dr Ross Kurinko

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Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 403-1

within GRI 403: Occupational Health and Safety

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