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Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
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15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
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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
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 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.
Published passport
Last reviewed 2026-08-03
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 407: Freedom of Association and Collective Bargaining
Disclosure GRI 407-1 · 2016
Last reviewed
2026-08-03
LRA educational guidance · Not issued or endorsed by Global Reporting Initiative
To prepare this disclosure
Disclosure focus
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.
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.
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 |
|---|---|---|---|
| Operations assessed | Operations considered in the freedom-of-association and collective-bargaining risk assessment. | Operational register, human-rights due diligence scope and assessment records. | Human Rights / Operations |
| At-risk operation types | Types of operations in which the rights may be violated or at significant risk. | Operation-level assessment, labor-relations review and legal or country analysis. | Human Rights / Labor Relations |
| At-risk supplier types | Types of suppliers in which the rights may be violated or at significant risk. | Supplier due diligence, procurement-category mapping and labor-rights assessment. | Procurement / Human Rights |
| Countries or geographical areas | Locations of the relevant operations and suppliers. | Country-risk analysis, ILO sources and local due-diligence records. | Human Rights / Legal |
| Risk basis | Whether the conclusion arises from operation or supplier type, geography, actual evidence or significant potential risk. | Assessment methodology and item-level rationale. | Human Rights / Sustainability |
| Measures taken | Measures taken in the reporting period intended to support freedom of association or collective bargaining. | Union-engagement records, supplier-remediation evidence, training and implementation records. | Labor Relations / Procurement |
| No-risk conclusion — if applicable | Evidence supporting a conclusion that no operations or suppliers were identified. | Completed assessment, screening results and management confirmation. | Human Rights / Sustainability |
| Methodology and omissions | Scope, assessment period, sources, limitations and any reasons for omission. | Methodology paper and GRI content-index documentation. | Sustainability Reporting |
＋ Show GRI 407-1 sub-elements (LRA working checklist)
Identify the types of operations and suppliers in which workers’ freedom-of-association or collective-bargaining rights may be violated or at significant risk.
Identify the countries or geographical areas in which the relevant operations and suppliers are located.
Describe the measures taken during the reporting period that were intended to support these rights.
Do not substitute collective-bargaining coverage, general supplier screening or an absence-of-complaints statement for the required risk identification.
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
Professional preparation tools for GRI 407-1 — free with verified email access. Enter the code we send you once and use downloads, report links and the LRA AI Assistant for 24 hours.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We assessed freedom of association and collective bargaining as specific human rights rather than using a general labor-risk score. | The published response does not support this human-reviewed assurance 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. | The published response does not support this human-reviewed assurance 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. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The risk threshold is not limited to confirmed incidents or complaints. | The published response does not support this human-reviewed assurance 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. | The published response does not support this human-reviewed assurance 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. | The published response does not support this human-reviewed assurance 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. | 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 classify suppliers as GRI 407-1 risks solely because they had general ESG, child-labor, forced-labor or environmental risk. | The published response does not support this human-reviewed assurance 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. | 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 treat the absence of complaints as sufficient evidence that no significant risk exists. | The published response does not support this human-reviewed assurance 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. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| We described measures taken in the reporting period. | The published response does not support this human-reviewed assurance 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. | 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 present a longstanding policy as a current-period measure without evidence of implementation or application. | The published response does not support this human-reviewed assurance 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. | 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 disclosure uses operation or supplier types and geographical information consistent with the underlying assessment. | The published response does not support this human-reviewed assurance 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. | 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. |
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
Illustrative examples
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.
Company reports
How companies report GRI 407-1 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
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
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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.
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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 review Hide 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.
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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 407-1
within GRI 407: Freedom of Association and Collective Bargaining
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