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GRI Training Partner GRI 412 · Human Rights Assessment · Disclosure GRI 412-3

Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening

GRI 412-3 · 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

Human rights clauses and human rights screening are alternative qualifying routes. An agreement need not meet both conditions. Generic legal-compliance wording or anti-money-laundering, sanctions, financial, environmental or anti-corruption screening alone does not qualify as human-rights screening.

Calculate the percentage using significant investment agreements or contracts with a qualifying human rights clause or screening as the numerator and all significant investment agreements and contracts in the defined reporting population as the denominator.

Document transaction types, period, stage, significance threshold, clause evidence, screening criteria and whether each qualifying agreement met the clause route, the screening route or both. Do not mix supplier screening under Disclosure 414-1 into this population.

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.

  • Definition of significant investment agreements and contracts

    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 definition of significant investment agreements and contracts.

    Watch for The published response for definition of significant investment agreements and contracts is incomplete or does not match the supporting records.

  • Complete significant agreement and contract population

    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 complete significant agreement and contract population.

    Watch for The published response for complete significant agreement and contract population is incomplete or does not match the supporting records.

  • Human rights clause present

    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 human rights clause present.

    Watch for The published response for human rights clause present is incomplete or does not match the supporting records.

  • Human rights screening completed

    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 human rights screening completed.

    Watch for The published response for human rights screening completed is incomplete or does not match the supporting records.

  • Qualifying route, 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 qualifying route, numerator and denominator.

    Watch for The published response for qualifying route, numerator and denominator is incomplete or does not match the supporting records.

  • Total number, percentage, evidence 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 total number, percentage, evidence and approval.

    Watch for The published response for total number, percentage, evidence and approval is incomplete or does not match the supporting records.

Before you start

  • Have you defined and reconciled the complete population for definition of significant investment agreements and contracts?
  • 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 412-3 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 412-3: Definition of significant investment agreements and contracts; Complete significant agreement and contract population; Human rights clause present; Human rights screening completed; Qualifying route, numerator and denominator; Total number, percentage, evidence 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 412-3: Definition of significant investment agreements and contracts; Complete significant agreement and contract population; Human rights clause present; Human rights screening completed; Qualifying route, numerator and denominator; Total number, percentage, evidence 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

Document transaction types, period, stage, significance threshold, clause evidence, screening criteria and whether each qualifying agreement met the clause route, the screening route or both. Do not mix supplier screening under Disclosure 414-1 into this population.

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

  • Definition of significant investment agreements and contracts is reported accurately and completely.

    Risk The response omits, misclassifies or overstates definition of significant investment agreements and contracts.

    Evidence to check Approved source records, calculations and review evidence supporting definition of significant investment agreements and contracts.

  • Complete significant agreement and contract population is reported accurately and completely.

    Risk The response omits, misclassifies or overstates complete significant agreement and contract population.

    Evidence to check Approved source records, calculations and review evidence supporting complete significant agreement and contract population.

  • Human rights clause present is reported accurately and completely.

    Risk The response omits, misclassifies or overstates human rights clause present.

    Evidence to check Approved source records, calculations and review evidence supporting human rights clause present.

  • Human rights screening completed is reported accurately and completely.

    Risk The response omits, misclassifies or overstates human rights screening completed.

    Evidence to check Approved source records, calculations and review evidence supporting human rights screening completed.

  • Qualifying route, numerator and denominator is reported accurately and completely.

    Risk The response omits, misclassifies or overstates qualifying route, numerator and denominator.

    Evidence to check Approved source records, calculations and review evidence supporting qualifying route, numerator and denominator.

  • Total number, percentage, evidence and approval is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total number, percentage, evidence and approval.

    Evidence to check Approved source records, calculations and review evidence supporting total number, percentage, evidence and approval.

Evidence pack to prepare

Common reporting gaps

  • Requiring both a human rights clause and screening instead of applying the stated or logic.
  • Counting generic compliance clauses or non-human-rights screening as qualifying.
  • Excluding uncovered significant agreements from the denominator.
  • Mixing supplier contracts or supplier social screening without a documented investment-agreement scope.
  • 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 412-3

within GRI 412: Human Rights Assessment

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