Disclosure focus
It also requires the status of the 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.
An incident can be a formal legal action or complaint or an instance of non-compliance identified through an established organizational procedure. The disclosure is therefore not limited to substantiated or finally determined violations.
When compiling the information, the organization should include incidents involving workers performing its activities and communities likely to be affected by existing or planned activities.
The information can be presented in aggregate. Confidential case-level details do not need to be disclosed publicly.
Policies, due diligence, consultation and FPIC processes belong primarily under Disclosure 3-3 and do not replace the quantitative and status information required by GRI 411-1.
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.
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Incident sources and population
Indigenous Relations / Community Relations / LegalFormal complaints, legal actions and identified non-compliance involving workers or affected communities.
Evidence Grievance registers, legal matters, project records, audits and monitoring systems.
Watch for The published response for incident sources and population is incomplete or does not match the supporting records.
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Total identified incidents
Sustainability Reporting / Human RightsTotal incidents identified during the reporting period.
Evidence Consolidated and de-duplicated incident register.
Watch for The published response for total identified incidents is incomplete or does not match the supporting records.
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Incidents reviewed
Case owner / LegalIncidents reviewed through the organization’s formal process.
Evidence Investigation and review records.
Watch for The published response for incidents reviewed is incomplete or does not match the supporting records.
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Remediation being implemented
Project / Community RelationsIncidents with remediation plans in progress.
Evidence Remediation plans, owners and progress records.
Watch for The published response for remediation being implemented is incomplete or does not match the supporting records.
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Remediation implemented and reviewed
Management / Human RightsIncidents with completed remediation whose results were reviewed through routine management processes.
Evidence Completion evidence and management-review records.
Watch for The published response for remediation implemented and reviewed is incomplete or does not match the supporting records.
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No longer subject to action
Case ownerIncidents requiring no further organizational action.
Evidence Closure records and closure rationale.
Watch for The published response for no longer subject to action is incomplete or does not match the supporting records.
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Prior-period remediation
Human Rights / LegalOlder incidents still under action, reported separately from the current-period total where useful.
Evidence Prior-period register and remediation tracker.
Watch for The published response for prior-period remediation is incomplete or does not match the supporting records.
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Methodology and privacy
Sustainability Reporting / LegalIncident definition, period rule, duplicate treatment, aggregation and reasons for omission.
Evidence Methodology note and legal or privacy review.
Watch for The published response for methodology and privacy is incomplete or does not match the supporting records.
Before you start
- Which formal processes can register or identify incidents involving the rights of indigenous peoples?
- Have community, worker, project, legal, grievance, security, land-access and cultural-heritage records been considered?
- Does the compilation include workers performing the organization’s activities?
- Does it include communities likely to be affected by existing or planned activities?
- Have internal community labels been mapped to the terminology and criteria used for indigenous peoples?
- Which records meet the GRI incident definition?
- Are formal complaints included regardless of whether they were later substantiated?
- Have duplicate records across systems been removed?
- What is the total number of incidents identified during the reporting period?
- Which incidents were reviewed by the organization?
- Which incidents have remediation plans being implemented?
- Which incidents have implemented remediation whose results were reviewed?
- Which incidents are no longer subject to action?
- Are prior-period incidents with ongoing remediation separated from the current-period total?
- Can every disclosed figure and status be traced to formal records?
- Can the information be disclosed without creating privacy, safety or cultural risks?
How to prepare it
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 incident records for [reporting period] relating to possible or identified violations of the rights of indigenous peoples. Include records from: community and worker grievance mechanisms; legal and regulatory matters; land-access, resettlement and cultural-heritage registers; project consultation and stakeholder-engagement systems; security incidents; audits and formal monitoring programmes; and other applicable formal procedures. For each anonymized incident, provide: incident ID; date registered or identified; source system; affected worker or community population; internal classification; right or issue involved; 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 current-period total.
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 incident records for [reporting period] relating to possible or identified violations of the rights of indigenous peoples. Include records from: community and worker grievance mechanisms; legal and regulatory matters; land-access, resettlement and cultural-heritage registers; project consultation and stakeholder-engagement systems; security incidents; audits and formal monitoring programmes; and other applicable formal procedures. For each anonymized incident, provide: incident ID; date registered or identified; source system; affected worker or community population; internal classification; right or issue involved; 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 current-period total.
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 compilation includes incidents involving workers performing the organization’s activities and communities likely to be affected by existing or planned activities.
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 411-1 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We applied the GRI definition of an 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 incident population includes applicable formal complaints, legal actions and identified instances of non-compliance.
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 substantiated or finally confirmed violations.
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 considered incidents involving workers performing the organization’s activities.
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 considered incidents involving communities likely to be affected by existing or planned activities.
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 community, project, grievance, legal, security, audit and monitoring 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.
Duplicate records concerning the same incident were removed.
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 prior-period incidents with ongoing remediation.
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 incident total reconciles to the consolidated 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.
The status and actions taken are mapped to the four references specified by GRI 411-1.
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.
We identified 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.
We identified 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.
We identified 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.
We identified 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, negotiated and escalated 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 reported explicitly 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.
The incident count is presented as an exact whole number rather than an estimate or rounded figure.
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 create privacy, safety or cultural risks for affected peoples.
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 unavailable required information is addressed through the applicable GRI reason-for-omission requirements.
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 reporting-period and status cut-off rules 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 describes its Indigenous Peoples policy but provides no incident total.
- The report states that incidents occurred but does not provide a number.
- Only substantiated or confirmed violations are counted.
- Formal complaints are omitted because the investigation did not uphold them.
- Complaints registered with competent authorities are omitted.
- Incidents identified through audits or monitoring are omitted.
- Only community incidents are considered and worker incidents are omitted.
- Only existing operations are considered and communities affected by planned activities are omitted.
- The same incident is counted in several systems.
- Complainants, meetings or remediation actions are counted instead of incidents.
- Current-period incidents are combined with prior-period cases still under remediation.
- The report presents only open and closed cases.
- The four required status and action references are not addressed.
- Implemented remediation is disclosed without indicating whether its results were reviewed.
- The report requires every case to be described publicly, creating confidentiality or safety risks.
- The organization reports no legal cases but does not consider grievance or monitoring records.
- The incident total is estimated or rounded.
- A zero result is not stated explicitly.
- Policies, consultation programmes or FPIC commitments are presented as substitutes for the incident disclosure.
- The disclosed total cannot be reconciled to formal records.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative synthetic example — Mining
During 2025, the organization identified three incidents involving the rights of indigenous peoples through its formal grievance and monitoring systems.
All three incidents were reviewed.
Remediation was being implemented for one incident.
Remediation had been implemented and its results reviewed for one incident.
One incident was no longer subject to action.
The information is reported in aggregate to protect the affected communities.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Utilities
Two formal incidents involving the rights of indigenous peoples were identified during the reporting period.
Both incidents were reviewed. A remediation plan was being implemented for one. Remediation for the other had been implemented and its results reviewed through the project’s routine management-review process.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Zero incidents
No incidents involving violations of the rights of indigenous peoples were identified during 2025. The four status and remediation references were therefore not applicable.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative treatment — complaint not substantiated
A formally registered community complaint was included in the incident total even though the review did not substantiate the allegation. The incident was reported as reviewed and no longer subject to action.
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.
Chailease Holding Company Limited
Review finding
Chailease Holding Company Limited’s 2024 Sustainability Report is described on the current page as reporting no violations involving the rights of indigenous peoples.
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Assessment
A direct zero-incidents response addresses the quantitative requirement in GRI 411-1(a). Where no incidents exist, the four status and remediation references in GRI 411-1(b) are not applicable.
LRA review note
The card should therefore:
- retain the zero-incidents result
- identify the exact page containing the direct answer
- remove the statement that outcomes or corrective measures are insufficient
- remove discrimination, forced-labor and general employee-incident information
- remove supplier social-assessment information
- classify the disclosure as an adequate zero-incidents response, subject to confirming the cited page in the report
Assessment
A report with zero incidents is not required to invent corrective actions or remediation outcomes.
Disclosure gap
The current card itself states that the report records no violations but then incorrectly treats missing corrective-action detail and supplier assessment as gaps.
SQM / Sociedad Química y Minera de Chile
Review finding
SQM’s 2024 Sustainability Report is described on the current page as stating that there were no violations involving the rights of indigenous peoples during the reporting period.
View full reviewHide full review
LRA review note
The card should:
- retain the direct zero-incidents answer on page 362
- state that the four incident-status and remediation references are not applicable because the total is zero
- remove corruption and legal-action information from page 364
- remove child-labor and health-and-safety information
- remove the claim that those unrelated topics are insufficiently quantified
- classify the report as an adequate zero-incidents disclosure for GRI 411-1
Assessment
Other human-rights or community-management disclosures can provide context but are not needed to complete a zero-incidents response under this disclosure.
Bottom line
The current card confirms the zero result but assesses unrelated disclosures as though they were part of GRI 411-1.
Zydus Wellness Limited
Review finding
Zydus Wellness Limited’s Integrated Annual Report 2024–25 reports zero incidents involving the rights of indigenous peoples on report page 86.
View full reviewHide full review
Assessment
The GRI content index on report page 99 directs users to page 86.
LRA review note
The card should:
- correct the substantive page reference from page 52 to page 86
- state explicitly that the reported value is zero
- recognize that status and remediation information is not applicable where no incidents exist
- remove manufactured-capital and customer-health-and-safety information
- remove the absence of case outcomes or mitigation measures as a gap
- classify the disclosure as an adequate zero-incidents response
Assessment
The surrounding Human Rights section provides policy and grievance-mechanism context, but this context is not a substitute for—and is not needed to supplement—the direct zero result.
Bottom line
Zydus reports: zero incident of violations involving rights of indigenous people on report page 86, while its GRI index maps 411-1 to that page.
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Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 411-1
within GRI 411: Rights of Indigenous Peoples
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