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GRI 409: Forced or Compulsory Labor·Disclosure GRI 409-1

Operations and suppliers at significant risk for incidents of forced or compulsory labor

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 409: Forced or Compulsory Labor 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 409: Forced or Compulsory Labor

Disclosure GRI 409-1 · 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
9LRA preparation fields 18claims to verify 14evidence areas

Disclosure focus

This disclosure requires the organization to identify operations and suppliers considered to have significant risk for incidents of forced or compulsory labor.

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 confirmed forced-labor incident has been identified.

The organization should also describe measures taken during the reporting period that were intended to contribute to the elimination of all forms of forced or compulsory labor.

The disclosure does not require a percentage of operations or suppliers assessed, a complete inventory of all sites and suppliers or publication of every individual supplier name.

General supplier ESG screening, modern-slavery policies or human-rights training do not replace the required risk identification unless they provide information specific to forced or compulsory labor.

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
Risk-assessment population Operations and suppliers considered through the forced-labor due-diligence process. Operations register, supplier population and due-diligence scope. Human Rights / Procurement
Significant-risk operations Operations considered to have significant risk for forced or compulsory labor. Operation-level assessments, audits and risk mapping. Human Rights / Operations
Significant-risk suppliers Suppliers considered to have significant risk for forced or compulsory labor. Supplier due diligence, audits and procurement records. Procurement / Human Rights
Types of operations and suppliers The applicable operation and supplier types. Classification methodology and item-level mapping. Sustainability Reporting
Countries or geographical areas Locations of the relevant operations and suppliers. Country-risk analysis and location records. Human Rights / Legal
Forced-labor risk basis Evidence of involuntary work or menace of penalty and relevant indicators. Recruitment reviews, worker interviews, audits and external sources. Human Rights / Compliance
Measures taken Measures taken during the reporting period to contribute to elimination. Action plans, remediation logs, training and supplier engagement records. Human Rights / Procurement
No-risk conclusion — if applicable Evidence supporting the conclusion that no operation or supplier met the threshold. Completed assessment and management review. Human Rights / Sustainability
Methodology and omissions Scope, assessment period, aggregation, limitations and any reason for omission. Methodology paper and GRI content-index documentation. Sustainability Reporting
＋ Show GRI 409-1 sub-elements (LRA working checklist)

How to prepare it

Define the operations and supplier population considered through due diligence.
Apply the GRI definition of forced or compulsory labor.
Establish forced-labor-specific significant-risk criteria.
Assess operations for significant risk.
Assess suppliers, including relevant indirect suppliers, for significant risk.
Distinguish forced-labor risk from general labor or supplier ESG risk.
Identify the relevant types of operations and suppliers.
Identify the relevant countries or geographical areas.
Use relevant internal evidence and recognized international sources.
Identify measures actually taken during the reporting period.
Confirm that each measure was intended to contribute to the elimination of forced or compulsory labor.
If no risks were identified, retain the completed assessment supporting that conclusion.
Aggregate commercially sensitive information only where the required type and geographical information remain clear.
Apply a GRI reason for omission where required information cannot be reported.
Verify the final disclosure against GRI 409-1(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 forced-labor risk assessment for [reporting period]. For operations and suppliers considered to have significant risk, include: operation or supplier type; direct or indirect supplier status, where relevant; country or geographical area; forced-labor risk identified; indicators or evidence supporting the conclusion; source and assessment date; and measures taken during the reporting period. Please distinguish forced-labor risk from general labor, child-labor, health-and-safety and supplier ESG risks. 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 forced-labor risk assessment for [reporting period]. For operations and suppliers considered to have significant risk, include: operation or supplier type; direct or indirect supplier status, where relevant; country or geographical area; forced-labor risk identified; indicators or evidence supporting the conclusion; source and assessment date; and measures taken during the reporting period. Please distinguish forced-labor risk from general labor, child-labor, health-and-safety and supplier ESG risks. 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 forced-labor risk using operation and supplier type, geographical information and indicators of involuntary work or menace of a penalty. The assessment used [internal evidence] and [recognized external sources].

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 409-1 — 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 applied the GRI definition of forced or compulsory labor.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 assessment considers involuntary work and menace of a penalty.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 forced-labor risk from general labor or supplier ESG 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 operations considered to have 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 considered to have 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 did not limit the assessment 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.
We did not treat the absence of incidents as sufficient evidence of no 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 the applicable operation and supplier types.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 relevant countries or geographical areas.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Relevant recruitment intermediaries, labor agencies and indirect suppliers were not automatically excluded.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 conclusions are traceable to internal evidence or recognized external sources.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 actually taken during 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 contribute to the elimination of forced or compulsory labor.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 general training, audits or policies as forced-labor measures without establishing the connection.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 supplier or operation counts as mandatory GRI 409-1 metrics.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Where individual supplier names were withheld, the type and geographical information remained understandable or an appropriate reason for omission was reported.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 completed 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 unavailable required information is addressed through the applicable GRI reason-for-omission requirements.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 forced labor is prohibited but does not identify operations or suppliers at significant risk.
The report states that no incidents occurred but provides no risk-assessment conclusion.
Only confirmed incidents or audit findings are considered.
General labor or supplier ESG risk is presented as forced-labor risk.
Forced labor is combined with child labor or human trafficking without separate assessment.
The type of operation at significant risk is not identified.
The type of supplier at significant risk is not identified.
The relevant countries or geographical areas are not identified.
Only first-tier suppliers are considered despite relevant indirect-supplier risk.
Recruitment agencies and labor brokers are omitted from the supplier assessment.
A country-risk score is used without identifying the forced-labor indicator.
The absence of complaints is treated as proof of no significant risk.
The disclosure focuses on the number or percentage of suppliers assessed rather than the required risk information.
A coverage percentage is presented as though it were a GRI 409-1 metric.
General supplier audits are reported without showing that they addressed forced labor.
A longstanding policy is presented as a measure taken during the reporting period.
General human-rights training is presented without forced-labor-specific content.
Measures are presented as proof that the risk was eliminated.
Sensitive supplier names are omitted together with all required type and geographical information.
A no-risk conclusion cannot be traced to an assessment.
Required information is omitted without an applicable 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
Cut-and-sew operations using migrant workers in Countries A and B were considered to have significant risk for incidents of forced labor because of recruitment debt and restrictions on workers’ ability to leave employment.
Labor agencies, textile processors and subcontracted facilities in Countries A, B and C were also considered to have significant risk.
During the reporting period, the organization prohibited recruitment fees, required reimbursement of identified fees, strengthened labor-agency contracts and completed worker interviews and forced-labor-specific audits.

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

Illustrative example 2

Illustrative synthetic example — Food processing and logistics
Seasonal packing operations in Country D and third-party logistics providers and labor agencies in Regions E and F were considered to have significant forced-labor risk.
The assessment identified recruitment debt, compulsory deposits and retention of worker documents as relevant indicators.
Measures taken during the reporting period included stronger recruitment controls, contract revisions, worker interviews and supplier corrective-action plans.

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

Illustrative example 3

Illustrative synthetic example — No significant risks identified
The organization assessed its operations and suppliers using activity type, geographical information and forced-labor indicators. It did not identify operations or suppliers considered to have significant risk under GRI 409-1.
During the reporting period, the organization continued recruitment-agency monitoring and worker-access controls intended to prevent forced labor.

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

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

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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 409-1

within GRI 409: Forced or Compulsory Labor

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This guide covers the significant-risk operations and suppliers and the measures taken during the reporting period as required by Disclosure 409-1.

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