Disclosure focus
This disclosure requires the organization to report incidents of non-compliance with regulations and voluntary codes concerning the health and safety impacts of products and services.
Report the incidents separately as:
regulatory non-compliance resulting in a fine or penalty;
regulatory non-compliance resulting in a warning; and
non-compliance with voluntary codes.
The disclosure concerns non-compliance rather than every complaint, defect, recall, adverse event or safety concern. Actual customer harm is not required, but an incident of non-compliance must be established.
Exclude incidents where the organization was determined not to be at fault and incidents related to product and service information or labelling.
Where an incident reported in the current period relates to an event from an earlier period, identify that fact.
If no incidents were identified, a brief statement confirming this is sufficient.
The disclosure does not require incident rates, fine values, corrective-action outcomes or a description of every individual case.
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 |
|---|---|---|---|
| Incident population | Potential product or service health and safety non-compliance matters identified across applicable systems. | Legal, regulatory, quality, recall, complaint and voluntary-code records. | Product Safety / Regulatory / Legal |
| Applicable requirement | Regulation or voluntary code associated with each matter. | Legal register, code documentation and assessment record. | Legal / Compliance |
| Non-compliance conclusion | Evidence that non-compliance occurred and that the organization was not determined to be without fault. | Regulator decision, investigation or code-review outcome. | Legal / Regulatory |
| Fine or penalty incidents | Regulatory incidents resulting in a fine or penalty. | Penalty notices, regulator decisions and payment records. | Legal / Finance |
| Warning incidents | Regulatory incidents resulting in a warning. | Warning letters, official notices and decisions. | Regulatory / Legal |
| Voluntary-code incidents | Incidents of non-compliance with voluntary health and safety codes. | Code assessment and internal or external determination. | Product Safety / Compliance |
| Labelling exclusion | Matters transferred to GRI 417-2. | Incident classification and labelling records. | Regulatory / Sustainability |
| Not-at-fault exclusion | Incidents excluded because the organization was determined not to be at fault. | Investigation and determination records. | Legal |
| Prior-period event link | Current-period incidents relating to events in earlier reporting periods. | Event, resolution and reporting-period dates. | Legal / Sustainability |
| Final category counts | Exact counts for the three required categories. | Controlled incident register and reconciliation. | Sustainability Reporting |
| Zero statement — if applicable | Confirmation that no relevant non-compliance was identified. | Cross-functional search and sign-off. | Legal / Product Safety |
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 product and service health and safety compliance register for [reporting period]. For each potentially relevant matter, include: controlled incident ID; product or service category; country and legal entity; applicable regulation or voluntary code; description of the alleged non-compliance; date of the underlying event; date non-compliance was determined; formal resolution date; whether the matter resulted in a fine or penalty; whether it resulted in a regulatory warning; whether it involved a voluntary-code breach; whether the organization was determined not to be at fault; whether the matter concerns information or labelling; recall, complaint or adverse-event references; evidence source; and reporting classification. Please also provide the reconciled counts for the three GRI 416-2 categories.
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 product and service health and safety compliance register for [reporting period]. For each potentially relevant matter, include: controlled incident ID; product or service category; country and legal entity; applicable regulation or voluntary code; description of the alleged non-compliance; date of the underlying event; date non-compliance was determined; formal resolution date; whether the matter resulted in a fine or penalty; whether it resulted in a regulatory warning; whether it involved a voluntary-code breach; whether the organization was determined not to be at fault; whether the matter concerns information or labelling; recall, complaint or adverse-event references; evidence source; and reporting classification. Please also provide the reconciled counts for the three GRI 416-2 categories.
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 were classified using the applicable product and service health and safety regulations and voluntary codes. Matters where the organization was determined not to be at fault and information or labelling incidents were excluded.
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 416-2 — free with verified email access. Enter the code we send you once and use downloads, report links and the LRA AI Assistant for 24 hours.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We identified the applicable product and service health and safety regulations. | 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 voluntary health and safety codes. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| We consolidated potentially relevant matters from all applicable source systems. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| We counted incidents rather than complaints, products, recalls, affected customers or regulator documents. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Customer complaints were not treated automatically as incidents of non-compliance. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Recalls and safety notices were not treated automatically as incidents of non-compliance. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Adverse-event and vigilance reports were not treated automatically as incidents of non-compliance. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Every included matter has evidence that non-compliance occurred. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Actual customer harm was not used as a condition for inclusion. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Hazards and near misses without established non-compliance were not included. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Incidents where the organization was determined not to be at fault were excluded. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Information and labelling incidents were excluded for GRI 417-2. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Regulatory incidents resulting in a fine or penalty were reported separately. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Regulatory incidents resulting in a warning were reported separately. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Voluntary-code incidents were reported separately. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Preliminary observations and information requests were not classified automatically as warnings. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Duplicate records across legal, quality, complaint and regulatory systems were removed. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Incidents relating to prior-period events were identified where applicable. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| A prior-period event formally resolved in the current period was not excluded automatically. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Older open matters were not counted solely because they remained active. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| Incident counts are exact whole numbers and were not estimated or rounded. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The overall total, where shown, reconciles to the three categories. | The published response does not support this human-reviewed assurance check. | Trace the statement to current approved records and the official IFRS source. |
| The zero statement, where used, is supported across the reporting boundary. | 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
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative synthetic example — Consumer goods manufacturing
During the reporting period:
one incident of regulatory non-compliance resulted in a fine;
one incident of regulatory non-compliance resulted in a warning; and
no incidents of non-compliance with voluntary codes were identified.
The warning related to a product event from the previous reporting period and was formally resolved in the current period.
Two additional product recalls were reviewed but were not included because they did not result from non-compliance with a relevant regulation or voluntary code.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Online retail and logistics
During the reporting period:
no regulatory incidents resulted in a fine or penalty;
one regulatory incident resulted in a warning; and
one incident involved non-compliance with a voluntary product-safety code.
One additional customer complaint was excluded because the review did not identify non-compliance. One product-information matter was transferred to GRI 417-2.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Zero incidents
No incidents of non-compliance with regulations or voluntary codes concerning the health and safety impacts of products and services were identified during 2026.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative treatment — organization not at fault
A regulator reviewed a customer-safety allegation and determined that the organization was not at fault. The matter was excluded from the GRI 416-2 counts.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative treatment — labelling
One incident concerned missing safety information on a product label. It was excluded from GRI 416-2 and reported under GRI 417-2.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Company reports
How companies report GRI 416-2 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Review finding
Zydus Lifesciences’ current card relies on the wrong disclosure.
Assessment
Report page 134 states that there were no incidents concerning product and service information and labelling and marketing communications. This information relates to GRI 417-2 and GRI 417-3, not GRI 416-2.
Report evidence
The substantive product-quality information is on report page 50. The report discloses:
- zero Class I recalls
- 54 Class II recalls
- 12 Form 483 observations or equivalent
- one FDA warning letter or equivalent
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Assessment
The GRI index maps Product Recalls to GRI 416-1 and GRI 416-2.
LRA review note
The card should:
- replace page 135 with report page 50 as the principal substantive source
- remove the product-information and labelling zero result from GRI 416-2
- recognize the one FDA warning letter as potentially relevant to the regulatory-warning category
- avoid treating every recall or Form 483 observation automatically as a GRI 416-2 incident
- determine whether any incidents resulted in a fine or penalty
- determine whether any incidents involved non-compliance with voluntary codes
- confirm how the 54 recalls were classified against the GRI requirement
- classify the disclosure as partial or requiring category-level reassessment
Assessment
Materiality and general risk-management information on page 148 is not required to complete Disclosure 416-2.
Bottom line
The official report contains separate product-recall, regulatory-observation and warning-letter information, while the cited labelling statement belongs to a different GRI disclosure.
Review finding
Owens Corning’s 2024 Sustainability Report states on report page 184 that the company had no material incidents of non-compliance concerning the health and safety of its products.
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Assessment
Its GRI index maps GRI 416-2(a) to None and GRI 416-2(b) to page 184.
Disclosure gap
The wording does not provide a fully aligned zero response because GRI 416-2 requires all incidents of non-compliance, not only incidents classified as material.
LRA review note
The card should:
- remove the parental-leave return-to-work figure
- remove the SCS Global Services independence and competence statement
- use report page 184 as the substantive reference
- quote or paraphrase the company’s no material incidents wording accurately
- explain that no material incidents does not necessarily mean zero incidents
- assess whether the company can confirm zero incidents across the three GRI categories
- classify the response as partial or imprecise rather than a complete zero disclosure
Assessment
No additional governance or assurance narrative is required solely for GRI 416-2.
Bottom line
Owens Corning’s report uses a materiality qualifier, while its GRI index indicates that the detailed incident-count requirement is not separately reported.
Review finding
Thai Beverage provides an adequate zero-incidents response on report page 92.
Report evidence
The report states that:
- there were zero incidents of non-compliance with regulations or voluntary codes concerning the health and safety impacts of products and services
- no regulatory incidents resulted in a fine, penalty or warning
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Assessment
The broad zero statement is sufficient under GRI 416-2(b). Separate category details are not required when no incidents occurred.
LRA review note
The card should:
- use report page 92 as the substantive reference
- retain the zero-incidents conclusion
- remove all child-labor references
- remove all forced-labor references
- remove supply-chain-management gaps
- state that no prior-period incident identification is applicable unless an incident exists
- classify the disclosure as an adequate zero response
Bottom line
ThaiBev explicitly reports zero incidents of non-compliance concerning the health and safety impacts of products and services.
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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 416-2
within GRI 416: Customer Health and Safety
Related & explore
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Go deeper · GRI 416-2
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