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GRI 406: Non-discrimination·Disclosure GRI 406-1

Incidents of discrimination and corrective 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 406: Non-discrimination 2016 remains the applicable published GRI Topic Standard and is effective for reports or other materials published on or after 1 July 2018.

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Published passport

Last reviewed 2026-08-03
RK 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 406: Non-discrimination

Disclosure GRI 406-1 · 2016

Effective

2018-07-01

Official source: Open ↗

Last reviewed

2026-08-03

LRA educational guidance · Not issued or endorsed by Global Reporting Initiative

To prepare this disclosure
8LRA preparation fields 18claims to verify 14evidence areas 3report examples

Disclosure focus

This disclosure requires the organization to report the total number of incidents of discrimination during the reporting period.

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.

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
Incident population and sources Formal complaints, legal actions and identified instances of non-compliance involving internal and external stakeholders. HR, Ethics, Legal, Compliance, grievance, customer and supplier complaint registers. Ethics / Compliance / Legal / HR
Total incidents Total number of incidents of discrimination during the reporting period. Reconciled master incident register and counting methodology. Disclosure coordinator
Incidents reviewed Incidents reviewed through the organization’s formal process. Investigation records and review status. Case owner
Remediation being implemented Incidents for which remediation plans remain in progress. Remediation plans, action owners and implementation records. Case owner / Compliance
Remediation implemented and reviewed Incidents for which remediation was completed and results reviewed through routine management processes. Completed plans and management-review evidence. Compliance / Management
No longer subject to action Resolved, completed, withdrawn or other incidents requiring no further action. Closure records and documented closure basis. Case owner
Scope and classification mapping Stakeholder type, discrimination ground, reporting period and mapping from local labels. Methodology and case-taxonomy mapping. Sustainability Reporting / Legal
Privacy and omissions Aggregation, confidentiality and any reason for omission. Privacy assessment and GRI content-index documentation. Legal / Privacy
＋ Show GRI 406-1 sub-elements (LRA working checklist)

How to prepare it

Identify all formal systems and procedures through which incidents can be registered or identified.
Include relevant HR, Ethics, Compliance, Legal, grievance, customer, supplier and other stakeholder channels.
Map local case labels and discrimination grounds to the GRI definition.
Establish the reporting-period counting rule.
Consolidate records into one incident-level register.
Remove duplicate records concerning the same incident.
Include formally registered complaints regardless of whether they were substantiated.
Include applicable instances identified through audits or monitoring processes.
Calculate the total number of incidents.
Map the incidents to the four required status and action references.
Separate current-period incidents from older incidents that remain under remediation.
Reconcile the total and status information to source systems.
Aggregate information where necessary to protect confidentiality.
Apply a reason for omission where required information cannot be disclosed.
Verify the final disclosure against GRI 406-1 and its compilation requirement.

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

Professional preparation tools for GRI 406-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI Assistant.

Free · Community members
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 ↧

Assurance readiness

For each claim, check the evidence

Claim Risk Evidence to check
We included formal complaints, legal actions and identified instances of non-compliance that meet the GRI incident definition.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The incident population includes relevant internal and external stakeholders.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
We did not limit the total to confirmed or substantiated cases.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
We removed duplicate records concerning the same incident.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The published total reconciles to the master incident register.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The disclosure identifies incidents reviewed by the organization.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The disclosure identifies remediation plans being implemented.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The disclosure identifies incidents no longer subject to action.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Zero incidents are explicitly reported where applicable.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The disclosure does not reveal information that could identify affected persons.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance 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.The published response does not support this human-reviewed assurance 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

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative example 1

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 example 2

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 example 3

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 example 4

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.

Company reports

How companies report GRI 406-1 in practice

Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.

Real published reports
CRH plc
Construction Materials · Ireland · 2024
Open report →

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.

This provides:

the total number of incidents;

aggregate evidence that the incidents were reviewed; and

a general description of actions taken.

However, the disclosure does not clearly map the 23 incidents to:

remediation plans being implemented;

remediation plans implemented with results reviewed; and

incidents no longer subject to action.

Classify the disclosure as substantial but partial practice.

Remove all discussion of forced labour, product labelling and supplier commodity assessments because these matters do not support GRI 406-1.

The relevant information appears directly in CRH’s GRI Index on report page 103.

JD Logistics
Air Freight Transportation and Logistics · China · 2025
Open report →

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.
Food Production — Animal Source · Brazil · 2024
Open report →

Marfrig’s 2024 Integrated Report provides relevant information across more than one section.

Page 103 reports:

ten discrimination cases in Brazil;

one discrimination case in Uruguay;

corrective measures assessed and applied where complaints were substantiated; and

annual compliance training used to reduce the risk of recurrence.

Page 33 separately reports 20 combined incidents of harassment or discrimination in North America.

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.

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; or

how many were no longer subject to action.

Classify the disclosure as substantial partial practice rather than presenting 20 incidents as the complete GRI total.

Marfrig’s GRI Index points Disclosure 406-1 to page 103, while page 33 contains additional regional complaint-channel data.

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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 406-1

within GRI 406: Non-discrimination

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Go deeper · GRI 406-1

Learn to prepare this disclosure end-to-end

This guide covers the incident total and the four status and action references required by Disclosure 406-1.

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