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GRI Training Partner GRI 407 · Freedom of Association and Collective Bargaining · Disclosure GRI 407-1

Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk

GRI 407-1 · mandatory · metrics + narrative

This disclosure requires the organization to identify operations and suppliers in which workers’ rights to exercise freedom of association or collective bargaining may be violated or at significant risk.

Legal status

GRI 407: Freedom of Association and Collective Bargaining 2016 remains applicable and is effective for reports or other materials published on or after 1 July 2018. Continue to apply it until revised Labor Standards are final and effective.

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

Disclosure focus

The disclosure should identify the relevant types of operations and suppliers and the countries or geographical areas in which they are located.

The assessment is risk-based. An operation or supplier can fall within the disclosure even where no complaint or confirmed violation has been reported.

The organization must also describe measures taken during the reporting period that were intended to support workers’ freedom of association and collective bargaining rights.

A general statement of support, collective-bargaining coverage percentage, supplier ESG score or generic worker-feedback mechanism does not replace the required information.

The public disclosure does not need to name every site or supplier if the type and geographical information faithfully explains where the risk exists.

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.

  • Operations assessed

    Human Rights / Operations

    Operations considered in the freedom-of-association and collective-bargaining risk assessment.

    Evidence Operational register, human-rights due diligence scope and assessment records.

    Watch for The published response for operations assessed is incomplete or does not match the supporting records.

  • At-risk operation types

    Human Rights / Labor Relations

    Types of operations in which the rights may be violated or at significant risk.

    Evidence Operation-level assessment, labor-relations review and legal or country analysis.

    Watch for The published response for at-risk operation types is incomplete or does not match the supporting records.

  • At-risk supplier types

    Procurement / Human Rights

    Types of suppliers in which the rights may be violated or at significant risk.

    Evidence Supplier due diligence, procurement-category mapping and labor-rights assessment.

    Watch for The published response for at-risk supplier types is incomplete or does not match the supporting records.

  • Countries or geographical areas

    Human Rights / Legal

    Locations of the relevant operations and suppliers.

    Evidence Country-risk analysis, ILO sources and local due-diligence records.

    Watch for The published response for countries or geographical areas is incomplete or does not match the supporting records.

  • Risk basis

    Human Rights / Sustainability

    Whether the conclusion arises from operation or supplier type, geography, actual evidence or significant potential risk.

    Evidence Assessment methodology and item-level rationale.

    Watch for The published response for risk basis is incomplete or does not match the supporting records.

  • Measures taken

    Labor Relations / Procurement

    Measures taken in the reporting period intended to support freedom of association or collective bargaining.

    Evidence Union-engagement records, supplier-remediation evidence, training and implementation records.

    Watch for The published response for measures taken is incomplete or does not match the supporting records.

  • No-risk conclusion — if applicable

    Human Rights / Sustainability

    Evidence supporting a conclusion that no operations or suppliers were identified.

    Evidence Completed assessment, screening results and management confirmation.

    Watch for The published response for no-risk conclusion — if applicable is incomplete or does not match the supporting records.

  • Methodology and omissions

    Sustainability Reporting

    Scope, assessment period, sources, limitations and any reasons for omission.

    Evidence Methodology paper and GRI content-index documentation.

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

Before you start

  • Which operations have been assessed for freedom-of-association and collective-bargaining risk?
  • Which suppliers have been assessed for these specific rights?
  • Which operations or suppliers meet the threshold of possible violation or significant risk?
  • Is the risk linked to the type of operation or supplier, the geographical context, or both?
  • Which countries or geographical areas should be disclosed?
  • Are freedom of association and collective bargaining assessed separately where necessary?
  • Have confirmed violations been distinguished from significant risk?
  • Have we avoided relying only on the absence of complaints?
  • Which recognized external and internal sources support the risk assessment?
  • Are general social, forced-labor or child-labor risks being incorrectly mapped to GRI 407-1?
  • What measures were actually taken during the reporting period?
  • Was each reported measure intended to support freedom of association or collective bargaining?
  • Can every disclosed type and geographical area be traced to supporting evidence?
  • If no operations or suppliers were identified, is the conclusion supported by a documented assessment?
＋ Show GRI 407-1 sub-elements (LRA working checklist)

How to prepare it

Define the reporting scope and identify the operations and suppliers considered in the due-diligence process.
Establish criteria specific to freedom of association and collective bargaining.
Assess whether the rights may be violated or at significant risk because of the type of operation or supplier.
Assess whether the rights may be violated or at significant risk because of the country or geographical area.
Use relevant internal evidence and recognized external sources.
Distinguish freedom-of-association and collective-bargaining risks from general labor, child-labor, forced-labor or supplier ESG risks.
Identify the operation and supplier types meeting the disclosure threshold.
Identify the countries or geographical areas in which they are located.
Determine which measures were taken during the reporting period.
Confirm that each measure was intended to support the specified rights.
If no operations or suppliers were identified, document the assessment supporting that conclusion.
Retain item-level supporting evidence without assuming that every individual name must be published.
Address any unavailable information through the applicable GRI reason-for-omission requirements.
Verify the final disclosure against GRI 407-1(a)–(b).

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 freedom-of-association and collective-bargaining assessment for [reporting period]. For operations, include: the operation or activity type assessed; the country or geographical area; whether the risk concerns freedom of association, collective bargaining or both; whether the conclusion concerns possible violation, significant risk or an identified violation; the evidence and source supporting the conclusion; and measures taken during the reporting period. For suppliers, include: the supplier or supplier-category type; the tier, where relevant; the country or geographical area; the specific freedom-of-association or collective-bargaining risk; the evidence and source supporting the conclusion; and measures taken during the reporting period. If no operations or suppliers were identified, please provide the completed assessment supporting that conclusion.

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 freedom-of-association and collective-bargaining assessment for [reporting period]. For operations, include: the operation or activity type assessed; the country or geographical area; whether the risk concerns freedom of association, collective bargaining or both; whether the conclusion concerns possible violation, significant risk or an identified violation; the evidence and source supporting the conclusion; and measures taken during the reporting period. For suppliers, include: the supplier or supplier-category type; the tier, where relevant; the country or geographical area; the specific freedom-of-association or collective-bargaining risk; the evidence and source supporting the conclusion; and measures taken during the reporting period. If no operations or suppliers were identified, please provide the completed assessment supporting that conclusion.

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

The organization assessed freedom-of-association and collective-bargaining risk using [internal sources] and [recognized external sources]. The assessment considered the type of operation or supplier and the relevant country or geographical area.

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 407-1 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 assessed freedom of association and collective bargaining as specific human rights rather than using a general labor-risk score.

    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 identified operations in which the rights may be violated or at significant risk.

    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 identified suppliers in which the rights may be violated or at significant risk.

    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 risk threshold is not limited to confirmed incidents or complaints.

    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 identified risk is supported by the type of operation or supplier, the geographical context or both.

    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 identified the countries or geographical areas in which the relevant operations and suppliers are located.

    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 distinguished freedom-of-association risk from collective-bargaining risk where necessary.

    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 classify suppliers as GRI 407-1 risks solely because they had general ESG, child-labor, forced-labor or environmental risk.

    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 supplier assessment considered indirect suppliers where they were relevant and identifiable through the due-diligence process.

    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 treat the absence of complaints as sufficient evidence that no significant risk exists.

    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.

  • Where no operations or suppliers were identified, the conclusion is supported by a documented assessment.

    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 described measures taken in the reporting period.

    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.

  • Each reported measure was intended to support freedom of association or collective bargaining.

    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 present a longstanding policy as a current-period measure without evidence of implementation or application.

    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.

  • Collective-bargaining coverage under GRI 2-30 was not presented as a substitute for GRI 407-1.

    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 published disclosure uses operation or supplier types and geographical information consistent with the underlying assessment.

    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 sensitive individual supplier names have been aggregated without obscuring the required information.

    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.

Evidence pack to prepare

Common reporting gaps

  • The report states that the organization supports freedom of association but does not identify operations or suppliers at risk.
  • The report discloses collective-bargaining coverage but does not address GRI 407-1.
  • Only confirmed violations or complaints are considered.
  • The report states that there were no reported violations but does not disclose a risk-assessment conclusion.
  • General labor-risk ratings are used without identifying freedom-of-association or collective-bargaining risk.
  • Supplier environmental or safety screening is presented as evidence for GRI 407-1.
  • Forced-labor or child-labor risks are presented as though they satisfy GRI 407-1.
  • The types of operations at risk are not identified.
  • The types of suppliers at risk are not identified.
  • The relevant countries or geographical areas are not identified.
  • A site or supplier list is provided without explaining the specific rights risk.
  • Only direct suppliers are considered even though relevant indirect suppliers were identified.
  • A general country-risk label is used without a connection to the specified rights.
  • The organization makes unsupported claims about the quality of national labor-law systems.
  • Measures are listed without showing that they were taken during the reporting period.
  • Existing policies are presented as measures without evidence of current-period action.
  • General training or grievance channels are presented without a connection to the rights.
  • No-risk conclusions rely only on a lack of complaints.
  • The report quantifies suppliers assessed but does not identify the suppliers or categories at significant risk.
  • A single combined labor-rights statement prevents users from identifying the GRI 407-1 information.
  • Required information is omitted without applying a GRI reason for omission.

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 — Apparel manufacturing
The organization identified apparel factories using labor agencies in Country A as operations in which freedom-of-association rights were at significant risk. The risk arose from restrictions on workers’ ability to form independent organizations and from interference by labor intermediaries.
Logistics and cleaning suppliers operating in Region B were also identified as presenting significant collective-bargaining risk.
During the reporting period, the organization amended supplier requirements, engaged with worker representatives, provided rights-specific training to procurement staff and required remediation plans from affected suppliers.

Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.

Illustrative example 2

Illustrative synthetic example — Food processing and distribution
Seasonal agricultural operations in Country C and outsourced logistics providers in Region D were identified as presenting significant risk to collective-bargaining rights.
The conclusion was based on the use of temporary labor, limitations on independent representation and relevant geographical risk information.
Measures taken during the reporting period included engagement with labor providers, revision of contractual requirements, worker-representative meetings and supplier remediation addressing interference with association and bargaining rights.

Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.

Illustrative example 3

Illustrative synthetic example — No operations or suppliers identified
The organization assessed its operations and suppliers by operation and supplier type and by geographical area. It did not identify any operation or supplier in which freedom-of-association or collective-bargaining rights may be violated or at significant risk. The assessment used [sources]. During the reporting period, the organization continued [relevant measures].

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

Cogna Educação S.A.

Education Services · Brazil · 2024

Review finding

Cogna’s 2024 Integrated Report provides partial information relevant to GRI 407-1 on page 149.

Assessment

The report states that strategic suppliers undergo document screening covering labor and human-rights criteria. It also states that Cogna has received no reports of suppliers violating workers’ freedom-of-association or collective-bargaining rights.

Assessment

Cogna describes its Code of Conduct commitment to preserving labor-union relations and states that a dedicated labor-relations team maintains ongoing engagement with union representatives.

Report evidence

This information supports:

  • part of the organization’s general supplier due-diligence process
  • a statement concerning reported supplier violations
  • measures or arrangements that can support freedom of association and collective bargaining
View full reviewHide full review

Disclosure gap

However, the report does not clearly:

  • identify operation types in which the rights may be violated or at significant risk
  • identify supplier types meeting the GRI 407-1 risk threshold
  • identify relevant countries or geographical areas
  • demonstrate that the absence of reports is supported by a rights-specific significant-risk assessment
  • distinguish measures taken specifically during the 2024 reporting period from ongoing policies and structures

Assessment

Classify the disclosure as partial practice.

Bottom line

Cogna’s substantive page says that it has no reports of supplier violations and describes supplier screening, its Code of Conduct and its labor-relations function. That is not equivalent to identifying operations and suppliers where the rights may be violated or at significant risk.

London Luton Airport Operations Ltd.

Air Transportation — Airport Services · United Kingdom · 2024

Review finding

London Luton Airport’s 2024 Sustainability Report explicitly marks GRI 407-1 as N — Not reported in its GRI Index.

View full reviewHide full review

Assessment

The report therefore should not be described as providing GRI 407-1 coverage.

Disclosure gap

The following information does not satisfy the disclosure:

  • total supplier numbers and supplier spend
  • local procurement information
  • general collective-bargaining references
  • child-labor index information
  • community-relationship reviews
  • land-use actions

LRA review note

The card should state that the report does not identify:

  • operation or supplier types at risk
  • countries or geographical areas at risk
  • measures taken during the reporting period intended to support freedom of association and collective bargaining

Assessment

Classify the report as not reported.

Bottom line

The GRI Index marks both GRI 2-30 and GRI 407-1 as not reported.

China Airlines, Ltd.

Air Transportation — Airlines · Taiwan · 2024

Review finding

China Airlines provides partial information relevant to GRI 407-1 in its Sustainable Supply Chain Management section, mapped by the GRI Index to page 76.

Assessment

The company states that its operational bases and suppliers have not violated workers’ rights to freedom of association or collective bargaining.

Report evidence

It also describes:

  • a supplier risk-investigation mechanism
  • annual sustainability risk assessments
  • country-specific, sector-specific and social-risk screening
  • Supplier Code of Conduct requirements
  • supplier audits, monitoring and corrective-action processes
  • supplier engagement and capacity-building measures
View full reviewHide full review

Disclosure gap

However, the disclosure does not clearly:

  • identify operation types where the rights may be violated or at significant risk
  • identify supplier types meeting the specific GRI 407-1 threshold
  • identify countries or geographical areas considered at risk for these rights
  • distinguish general human-rights and labor-condition risk from freedom-of-association or collective-bargaining risk
  • demonstrate that the no-violation statement is also a no-significant-risk conclusion
  • identify which 2024 measures were specifically intended to support the two rights

Assessment

Classify the report as partial practice rather than complete disclosure.

Bottom line

China Airlines’ substantive disclosure and GRI index point to page 76. The company states that no violations occurred and describes extensive general supplier-risk processes, but its high-risk supplier information is not specifically attributed to freedom of association or collective bargaining.

Full evidence map with quotes and page numbers →

✓ Knowledge Hub AI Assistant · Human-in-the-loop
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Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 407-1

within GRI 407: Freedom of Association and Collective Bargaining

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