Disclosure focus
It also requires the organization to report the status of those incidents and actions taken, with reference to:
incidents reviewed by the organization;
remediation plans being implemented;
remediation plans implemented, with results reviewed through routine internal management review processes; and
incidents no longer subject to action.
The incident population includes relevant formal complaints, legal actions and identified instances of non-compliance involving internal or external stakeholders across the organization’s operations.
A formally registered complaint can be counted even if it is later not substantiated. The disclosure should therefore not be limited to confirmed cases.
The information can be reported in aggregate. The organization is not required to publish confidential case-level details.
Policies, commitments, grievance mechanisms and preventive measures are reported through Disclosure 3-3 where non-discrimination is a material topic. They do not replace the quantitative and status information required by GRI 406-1.
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.
-
Incident population and sources
Ethics / Compliance / Legal / HRFormal complaints, legal actions and identified instances of non-compliance involving internal and external stakeholders.
Evidence HR, Ethics, Legal, Compliance, grievance, customer and supplier complaint registers.
Watch for The published response for incident population and sources is incomplete or does not match the supporting records.
-
Total incidents
Disclosure coordinatorTotal number of incidents of discrimination during the reporting period.
Evidence Reconciled master incident register and counting methodology.
Watch for The published response for total incidents is incomplete or does not match the supporting records.
-
Incidents reviewed
Case ownerIncidents reviewed through the organization’s formal process.
Evidence Investigation records and review status.
Watch for The published response for incidents reviewed is incomplete or does not match the supporting records.
-
Remediation being implemented
Case owner / ComplianceIncidents for which remediation plans remain in progress.
Evidence Remediation plans, action owners and implementation records.
Watch for The published response for remediation being implemented is incomplete or does not match the supporting records.
-
Remediation implemented and reviewed
Compliance / ManagementIncidents for which remediation was completed and results reviewed through routine management processes.
Evidence Completed plans and management-review evidence.
Watch for The published response for remediation implemented and reviewed is incomplete or does not match the supporting records.
-
No longer subject to action
Case ownerResolved, completed, withdrawn or other incidents requiring no further action.
Evidence Closure records and documented closure basis.
Watch for The published response for no longer subject to action is incomplete or does not match the supporting records.
-
Scope and classification mapping
Sustainability Reporting / LegalStakeholder type, discrimination ground, reporting period and mapping from local labels.
Evidence Methodology and case-taxonomy mapping.
Watch for The published response for scope and classification mapping is incomplete or does not match the supporting records.
-
Privacy and omissions
Legal / PrivacyAggregation, confidentiality and any reason for omission.
Evidence Privacy assessment and GRI content-index documentation.
Watch for The published response for privacy and omissions is incomplete or does not match the supporting records.
Before you start
- What formal processes can register or identify incidents of discrimination?
- Have Legal, Compliance, Ethics, HR, customer complaints and other relevant systems been considered?
- Does the incident population include internal and external stakeholders?
- Which discrimination grounds and case labels map to the GRI definition?
- What reporting-period rule is used for the incident total?
- How are duplicate records across systems identified?
- Are formally registered but unsubstantiated complaints included?
- Are incidents identified through audits or monitoring programmes included?
- What is the total number of incidents during the reporting period?
- Which incidents were reviewed by the organization?
- Which incidents have remediation plans being implemented?
- Which incidents have implemented remediation plans whose results were reviewed?
- Which incidents are no longer subject to action?
- Are incidents from previous periods kept separate from the current-period total?
- Can every reported number be reconciled to formal records?
- Can the required information be disclosed without identifying affected persons?
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.
Please provide the discrimination-incident register for [reporting period]. Include incidents registered or identified through: HR and employee-relations channels; Ethics or speak-up systems; Legal and regulatory records; grievance mechanisms; audits or formal monitoring programmes; customer, supplier or business-partner complaint channels; and other applicable formal procedures. For each record, provide: anonymized incident ID; date registered or identified; stakeholder type; internal case classification; discrimination ground; source system; review status; remediation status; whether implemented remediation has been reviewed; whether the incident is no longer subject to action; and any linked duplicate record. Please also provide the reconciled total for the reporting period.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
Please provide the discrimination-incident register for [reporting period]. Include incidents registered or identified through: HR and employee-relations channels; Ethics or speak-up systems; Legal and regulatory records; grievance mechanisms; audits or formal monitoring programmes; customer, supplier or business-partner complaint channels; and other applicable formal procedures. For each record, provide: anonymized incident ID; date registered or identified; stakeholder type; internal case classification; discrimination ground; source system; review status; remediation status; whether implemented remediation has been reviewed; whether the incident is no longer subject to action; and any linked duplicate record. Please also provide the reconciled total for the reporting period.
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
Incidents include formal legal actions, registered complaints and instances of non-compliance identified through established procedures. The total covers relevant incidents involving internal and external stakeholders across the organization’s reporting scope.
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 406-1 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We included formal complaints, legal actions and identified instances of non-compliance that meet the GRI incident definition.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The incident population includes relevant internal and external stakeholders.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
Relevant HR, Ethics, Compliance, Legal, grievance and external-stakeholder complaint systems were reconciled.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
We did not limit the total to confirmed or substantiated cases.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
We removed duplicate records concerning the same incident.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The current-period total is separated from incidents originating in prior periods.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The published total reconciles to the master incident register.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
We mapped incident status and actions to the four references specified by GRI 406-1.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The disclosure identifies incidents reviewed by the organization.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The disclosure identifies remediation plans being implemented.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The disclosure identifies implemented remediation whose results were reviewed through routine management processes.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The disclosure identifies incidents no longer subject to action.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
Internal labels such as open, closed and substantiated were not used as substitutes without mapping.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
Zero incidents are explicitly reported where applicable.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
Incident counts are reported as whole numbers and are not rounded or estimated.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The disclosure does not reveal information that could identify affected persons.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
Any required information that cannot be reported is addressed through the applicable GRI reason for omission.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
The status cut-off and reporting period are documented and consistently applied.
Risk The published response does not support this human-reviewed assurance check.
Evidence to check Trace the statement to current approved records and the official IFRS source.
Evidence pack to prepare
Common reporting gaps
- The organization reports policies but no incident total.
- The report states that incidents occurred but does not provide a number.
- Only confirmed or substantiated incidents are counted.
- Only employee incidents are included.
- External-stakeholder incidents are omitted.
- Complaints to competent authorities are omitted.
- Incidents identified through audits or monitoring are omitted.
- Harassment incidents meeting the discrimination definition are excluded.
- The total combines discrimination with unrelated misconduct without a separate discrimination figure.
- The same incident is counted in several systems.
- Current-period incidents are combined with prior-period open cases.
- The report presents only open and closed cases.
- The four required status and action references are not addressed.
- Corrective actions are described without identifying the status of the incidents.
- Implemented remediation is disclosed without indicating whether its results were reviewed.
- A withdrawn or completed incident is not identified as no longer subject to action.
- The organization reports zero confirmed cases rather than zero formal incidents.
- A zero result is not clearly stated.
- Incident totals are estimated or rounded.
- The disclosure provides individual case details that create confidentiality risks.
- The disclosed total cannot be reconciled to the incident registers.
- A broad category such as harassment or discrimination prevents identification of the GRI incident total.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative synthetic example — Retail and distribution
During 2025, the organization recorded three incidents of discrimination through its formal complaint channels.
All three incidents were reviewed.
Remediation plans were being implemented for one incident.
Remediation plans had been implemented and their results reviewed for one incident.
One incident was no longer subject to action after the complaint was withdrawn and no further organizational action was required.
The information is presented in aggregate to protect confidentiality.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Construction and engineering
Five incidents of discrimination were registered during the reporting period, including four involving workers and one involving a contractor.
All five incidents were reviewed. Remediation was being implemented for two incidents, remediation had been implemented and reviewed for two incidents, and one incident was no longer subject to action.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Zero incidents
No incidents of discrimination were registered or identified through the organization’s formal processes during 2025. Accordingly, the four incident-status and remediation categories were not applicable.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative treatment — complaint not substantiated
A formally registered complaint was included in the incident total even though the investigation did not substantiate the allegation. The incident was reported as reviewed and no longer subject to action.
Scenarios to work through
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Real reports
How 3 companies report it
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
CRH plc
Review finding
CRH reports 23 instances of discrimination in 2024. It states that all were fully investigated and that policies and training were reinforced where necessary, with disciplinary action taken where appropriate.
Report evidence
This provides:
- the total number of incidents
- aggregate evidence that the incidents were reviewed
- a general description of actions taken
View full reviewHide full review
Disclosure gap
However, the disclosure does not clearly map the 23 incidents to:
- remediation plans being implemented
- remediation plans implemented with results reviewed
- incidents no longer subject to action
Assessment
Classify the disclosure as substantial but partial practice.
Disclosure gap
Remove all discussion of forced labour, product labelling and supplier commodity assessments because these matters do not support GRI 406-1.
Bottom line
The relevant information appears directly in CRH’s GRI Index on report page 103.
JD Logistics
JD Logistics’ 2025 ESG Report states that it had no incidents of employment discrimination during the reporting period.
This provides a zero figure for employment-related incidents. Where the report’s formal processes identified no incidents, the four status and remediation categories are not applicable.
The report also describes general human-rights remediation mechanisms, including possible apologies, position adjustments, termination and clawback of incentives. These are general procedures and should not be presented as corrective actions taken in response to actual 2025 discrimination incidents.
The principal remaining review point is scope: employment discrimination does not clearly demonstrate whether relevant incidents involving applicants, customers, suppliers or other external stakeholders were also included.
Classify the disclosure as partial because the reported zero is narrower than the full internal-and-external-stakeholder compilation requirement unless broader scope is evidenced elsewhere.
JD Logistics’ report expressly reports zero employment-discrimination incidents and separately describes its general remediation mechanisms.
Marfrig Global Foods S.A.
Review finding
Marfrig’s 2024 Integrated Report provides relevant information across more than one section.
Report evidence
Page 103 reports:
- ten discrimination cases in Brazil
- one discrimination case in Uruguay
- corrective measures assessed and applied where complaints were substantiated
- annual compliance training used to reduce the risk of recurrence
View full reviewHide full review
Assessment
Page 33 separately reports 20 combined incidents of harassment or discrimination in North America.
Disclosure gap
The report therefore contains substantial relevant information, but it does not clearly provide one consolidated GRI 406-1 total across all operations. The North American combined category also needs to be mapped to the GRI discrimination definition before it can be added to the total.
Disclosure gap
The report does not clearly map the incidents to all four required status and action references. A statement that corrective measures were applied in substantiated cases does not explain:
- how many incidents were reviewed
- how many had remediation being implemented
- how many had implemented remediation with results reviewed
- how many were no longer subject to action
Assessment
Classify the disclosure as substantial partial practice rather than presenting 20 incidents as the complete GRI total.
Bottom line
Marfrig’s GRI Index points Disclosure 406-1 to page 103, while page 33 contains additional regional complaint-channel data.
Ask the Knowledge Hub AI Assistant about this disclosure
Get practical answers for your reporting context.
Check your text
Paste one or two paragraphs. The fragment is used for this check only and is not stored in your conversation.
Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 406-1
within GRI 406: Non-discrimination
Related & explore
More in GRI 406 →Browse full catalogue →Search all disclosures →