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GRI Training Partner GRI 412 · Human Rights Assessment · Disclosure GRI 412-1

Operations that have been subject to human rights reviews or impact assessments

GRI 412-1 · mandatory

A record of what this disclosure asked for while it was in force, kept for readers working with reports written against it. It is not preparation guidance: the requirement no longer exists in the Global Reporting Initiative Standards.

Official Global Reporting Initiative source ↗

Disclosure focus

An operation can qualify through a human rights review or a human rights impact assessment; both are not required. A generic operational, financial, environmental, compliance or supplier audit qualifies only if it substantively reviews the operation's human rights impacts.

Calculate the percentage using operations subject to a qualifying review or impact assessment as the numerator and total operations in the relevant country population as the denominator. Document what counts as an operation and apply the reporting-period basis consistently.

Findings, responses, review type and supplier coverage can be useful context but do not replace the required country-level number and percentage.

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.

  • Country and total operations

    People / Human Rights / Sustainability Reporting

    Prepare and reconcile this field using the definitions, population and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculations and review evidence supporting country and total operations.

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

  • Operations subject to a qualifying human rights review or impact assessment

    People / Human Rights / Sustainability Reporting

    Prepare and reconcile this field using the definitions, population and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculations and review evidence supporting operations subject to a qualifying human rights review or impact assessment.

    Watch for The published response for operations subject to a qualifying human rights review or impact assessment is incomplete or does not match the supporting records.

  • Review type, scope, date and validity

    People / Human Rights / Sustainability Reporting

    Prepare and reconcile this field using the definitions, population and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculations and review evidence supporting review type, scope, date and validity.

    Watch for The published response for review type, scope, date and validity is incomplete or does not match the supporting records.

  • Country-level numerator and denominator

    People / Human Rights / Sustainability Reporting

    Prepare and reconcile this field using the definitions, population and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculations and review evidence supporting country-level numerator and denominator.

    Watch for The published response for country-level numerator and denominator is incomplete or does not match the supporting records.

  • Country-level number and percentage

    People / Human Rights / Sustainability Reporting

    Prepare and reconcile this field using the definitions, population and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculations and review evidence supporting country-level number and percentage.

    Watch for The published response for country-level number and percentage is incomplete or does not match the supporting records.

  • Methodology, source and approval

    People / Human Rights / Sustainability Reporting

    Prepare and reconcile this field using the definitions, population and calculation basis in the reviewed Disclosure focus.

    Evidence Approved source records, calculations and review evidence supporting methodology, source and approval.

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

Before you start

  • Have you defined and reconciled the complete population for country and total operations?
  • Have you separated mandatory GRI requirements from recommendations and optional supporting context?
  • Can every reported number, category, definition, exclusion and conclusion be traced to current source evidence?
  • Have privacy, confidentiality, missing information and any applicable GRI 1 reason for omission been documented?
＋ Show GRI 412-1 sub-elements (LRA working checklist)

How to prepare it

Define the reporting population, boundary, period and applicable terminology before collecting data.
Collect the source records for each human-reviewed preparation field and retain record-level traceability.
Apply the calculation, classification and denominator rules in the Disclosure focus; document assumptions, exclusions and prior-period treatment.
Reconcile totals and populations to authoritative registers and neighbouring GRI disclosures where relevant.
Review the final disclosure against every mandatory element and obtain documented owner and editorial approval.

Request the data

Request the disclosure evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Provide the reporting-period records and reconciliations for Disclosure 412-1: Country and total operations; Operations subject to a qualifying human rights review or impact assessment; Review type, scope, date and validity; Country-level numerator and denominator; Country-level number and percentage; Methodology, source and approval. Include definitions, population, period, methods, exclusions, owners and approvals.

Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.

Better request

Provide the reporting-period records and reconciliations for Disclosure 412-1: Country and total operations; Operations subject to a qualifying human rights review or impact assessment; Review type, scope, date and validity; Country-level numerator and denominator; Country-level number and percentage; Methodology, source and approval. Include definitions, population, period, methods, exclusions, owners and approvals.

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

Findings, responses, review type and supplier coverage can be useful context but do not replace the required country-level number and percentage.

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.

Check

For each claim, check the evidence

  • Country and total operations is reported accurately and completely.

    Risk The response omits, misclassifies or overstates country and total operations.

    Evidence to check Approved source records, calculations and review evidence supporting country and total operations.

  • Operations subject to a qualifying human rights review or impact assessment is reported accurately and completely.

    Risk The response omits, misclassifies or overstates operations subject to a qualifying human rights review or impact assessment.

    Evidence to check Approved source records, calculations and review evidence supporting operations subject to a qualifying human rights review or impact assessment.

  • Review type, scope, date and validity is reported accurately and completely.

    Risk The response omits, misclassifies or overstates review type, scope, date and validity.

    Evidence to check Approved source records, calculations and review evidence supporting review type, scope, date and validity.

  • Country-level numerator and denominator is reported accurately and completely.

    Risk The response omits, misclassifies or overstates country-level numerator and denominator.

    Evidence to check Approved source records, calculations and review evidence supporting country-level numerator and denominator.

  • Country-level number and percentage is reported accurately and completely.

    Risk The response omits, misclassifies or overstates country-level number and percentage.

    Evidence to check Approved source records, calculations and review evidence supporting country-level number and percentage.

  • Methodology, source and approval is reported accurately and completely.

    Risk The response omits, misclassifies or overstates methodology, source and approval.

    Evidence to check Approved source records, calculations and review evidence supporting methodology, source and approval.

Evidence pack to prepare

Common reporting gaps

  • Reporting percentage without number, number without percentage or no country split.
  • Counting generic audits that do not substantively assess human rights impacts.
  • Using employees, legal entities, projects or sites interchangeably with operations.
  • Using cumulative lifetime reviews without explaining the current-period basis.
  • Treating optional context, an LRA preparation control or a neighbouring disclosure as a mandatory element of this disclosure.
  • Publishing an estimate, exclusion, partial population or unsupported conclusion without its method and evidence.
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Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 412-1

within GRI 412: Human Rights Assessment

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