Skip to the disclosure focus
Courses

GRI Training Partner GRI 406 · Non-discrimination · Disclosure GRI 406-1

Incidents of discrimination and corrective actions taken

GRI 406-1 · mandatory · metrics + narrative

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

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.

Start preparing ↓ Official Global Reporting Initiative source ↗ Compare 3 real reports

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 / HR

    Formal 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 coordinator

    Total 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 owner

    Incidents 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 / Compliance

    Incidents 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 / Management

    Incidents 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 owner

    Resolved, 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 / Legal

    Stakeholder 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 / Privacy

    Aggregation, 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?
＋ 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

Download preparation tools for GRI 406-1 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access
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 ↧

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 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.

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.

Real published reports

CRH plc

Construction Materials · Ireland · 2024

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

Air Freight Transportation and Logistics · China · 2025

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

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.

Full evidence map with quotes and page numbers →

✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

Ask the Knowledge Hub AI Assistant about this disclosure

Get practical answers for your reporting context.

Try How do I prepare GRI 406-1? What data do I need to collect? Where can I see a real-report example? What mistakes should I avoid?

Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 406-1

within GRI 406: Non-discrimination

Open official source →

Related & explore

Browse all disclosures →

More in GRI 406 →Browse full catalogue →Search all disclosures →

How this library is built 1,211 published reports indexed 315,012 pages with page-level citations 272 published cards in the active catalogue
/en/knowledge-hub/disclosure-cards/gri-406-1/