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GRI Training Partner GRI 412 · Human Rights Assessment · Disclosure GRI 412-2

Employee training on human rights policies or procedures

GRI 412-2 · 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.

Disclosure focus

Report total training hours, not average hours per employee. Calculate the percentage using employees who completed qualifying training during the reporting period as the numerator and total employees as the denominator, reconciling the employee population to Disclosure 2-7.

Training must concern the organisation's human rights policies or procedures and aspects relevant to operations. Generic ethics, diversity, occupational health and safety, compliance or code-acknowledgement training qualifies only to the extent that relevant human-rights content is substantiated.

Retain session duration, attendance and completion evidence, treat repeated training and e-learning consistently and deduplicate employees for the percentage. Contractors and other workers are not automatically included in the employee denominator.

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.

  • Qualifying human-rights training courses and content

    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 qualifying human-rights training courses and content.

    Watch for The published response for qualifying human-rights training courses and content is incomplete or does not match the supporting records.

  • Course duration and completion records

    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 course duration and completion records.

    Watch for The published response for course duration and completion records is incomplete or does not match the supporting records.

  • Total qualifying training hours

    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 total qualifying training hours.

    Watch for The published response for total qualifying training hours is incomplete or does not match the supporting records.

  • Unique employees completing qualifying training

    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 unique employees completing qualifying training.

    Watch for The published response for unique employees completing qualifying training is incomplete or does not match the supporting records.

  • Total employee denominator reconciled to Disclosure 2-7

    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 total employee denominator reconciled to disclosure 2-7.

    Watch for The published response for total employee denominator reconciled to disclosure 2-7 is incomplete or does not match the supporting records.

  • Employee training percentage and calculation basis

    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 employee training percentage and calculation basis.

    Watch for The published response for employee training percentage and calculation basis is incomplete or does not match the supporting records.

Before you start

  • Have you defined and reconciled the complete population for qualifying human-rights training courses and content?
  • 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 412-2 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 412-2: Qualifying human-rights training courses and content; Course duration and completion records; Total qualifying training hours; Unique employees completing qualifying training; Total employee denominator reconciled to Disclosure 2-7; Employee training percentage and calculation basis. 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 412-2: Qualifying human-rights training courses and content; Course duration and completion records; Total qualifying training hours; Unique employees completing qualifying training; Total employee denominator reconciled to Disclosure 2-7; Employee training percentage and calculation basis. 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

Retain session duration, attendance and completion evidence, treat repeated training and e-learning consistently and deduplicate employees for the percentage. Contractors and other workers are not automatically included in the employee denominator.

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

  • Qualifying human-rights training courses and content is reported accurately and completely.

    Risk The response omits, misclassifies or overstates qualifying human-rights training courses and content.

    Evidence to check Approved source records, calculations and review evidence supporting qualifying human-rights training courses and content.

  • Course duration and completion records is reported accurately and completely.

    Risk The response omits, misclassifies or overstates course duration and completion records.

    Evidence to check Approved source records, calculations and review evidence supporting course duration and completion records.

  • Total qualifying training hours is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total qualifying training hours.

    Evidence to check Approved source records, calculations and review evidence supporting total qualifying training hours.

  • Unique employees completing qualifying training is reported accurately and completely.

    Risk The response omits, misclassifies or overstates unique employees completing qualifying training.

    Evidence to check Approved source records, calculations and review evidence supporting unique employees completing qualifying training.

  • Total employee denominator reconciled to Disclosure 2-7 is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total employee denominator reconciled to disclosure 2-7.

    Evidence to check Approved source records, calculations and review evidence supporting total employee denominator reconciled to disclosure 2-7.

  • Employee training percentage and calculation basis is reported accurately and completely.

    Risk The response omits, misclassifies or overstates employee training percentage and calculation basis.

    Evidence to check Approved source records, calculations and review evidence supporting employee training percentage and calculation basis.

Evidence pack to prepare

Common reporting gaps

  • Reporting average hours instead of total hours or sessions instead of hours.
  • Counting assigned but incomplete training or generic training without qualifying content.
  • Mixing employees with contractors or double counting employees attending multiple sessions.
  • Reporting attendee count without the employee percentage or using the wrong denominator.
  • 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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Dr Ross Kurinko

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Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 412-2

within GRI 412: Human Rights Assessment

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