C6 and C7 Human Rights Disclosures: Complaints, Confirmed Incidents and Remediation

A controlled case lifecycle keeps intake information separate from the conclusion reported under C7.

Human-rights case data are unusually sensitive. A weak reporting process can understate serious impacts, inflate unverified allegations into confirmed facts, expose affected individuals, prejudice an investigation or create an unsupported claim that remediation has been completed.

The key control is not a more detailed public narrative. It is a restricted case register that preserves the distinction between intake, investigation, confirmation and remedy, and then produces proportionate aggregate information for the sustainability report.

MICRO RELIEF / C6(a), C6(c), C7(a) and C7(c) are marked voluntary for undertakings with 10 employees or fewer in the Commission-adopted text. The reporting team should record the relief deliberately; it should not silently treat a non-reported datapoint as “not applicable”.

The 2026 Commission-adopted C7 text uses the term “confirmed incidents” but does not itself prescribe one investigation protocol. Historical Commission guidance is useful because it describes a confirmed incident as a legal action or complaint registered through a formal process, or an instance of non-compliance identified through established procedures such as audits, monitoring or grievance mechanisms. This guidance should be labelled historical and used as a design input, not copied as if it were a new binding definition.

A defensible internal rule states who may confirm, what evidence standard is applied, how appeals or ongoing proceedings are treated, and which date determines inclusion in the reporting period. The rule should be stable enough for comparatives and flexible enough to respect local labour, whistleblower, criminal and civil procedure.

The reporting population is produced after investigation and cut-off controls, not at the moment of intake.

Define the reporting perimeter. Map own workforce separately from value-chain workers, affected communities, consumers and end-users.

Inventory policies and mechanisms. Confirm the current approved document, population covered, access channels, language, escalation and anti-retaliation controls.

Create a case taxonomy. Record intake type, issue category, source, entity or relationship, investigation status and confidentiality level.

Apply the confirmation rule. Identify the authorised decision-maker, evidence threshold, finality status and reporting-period cut-off.

Separate counts and narratives. Produce an own-workforce conclusion for C7(a) and a separately evidenced awareness conclusion for C7(c).

Assess remediation. Distinguish immediate protection, investigation, corrective action, remedy to affected people, prevention of recurrence and effectiveness evidence.

Perform legal and privacy review. Check personal data, whistleblower protection, privilege, defamation risk, ongoing proceedings and local disclosure restrictions.

Approve aggregate public wording. Reconcile the answer to the restricted register, disclosure index and the Option A/Option B basis statement.

The undertaking normally has direct access to own-workforce case channels and HR investigations. C7(c) is different: it asks whether the undertaking is aware of confirmed incidents involving specified external populations. A “no” answer is therefore a conclusion based on a defined awareness process, not a claim of omniscience.

The evidence room can be much more detailed than the public report, but both must reconcile.

Use aggregate categories and avoid names, exact locations or combinations of facts that allow re-identification.

Apply data minimisation: the sustainability report rarely needs the full case file, witness statements or medical information.

Do not publish a conclusion that could prejudice an investigation, appeal, judicial proceeding or protected whistleblower process.

Record the legal basis and approval for any omission or high-level wording; “confidential” should not become a blanket substitute for analysis.

Keep public disclosures consistent with financial statements, legal reports, regulatory filings and other corporate communications.

ILLUSTRATIVE SCENARIO / A 180-employee group receives a complaint that a supervisor discriminated in promotion decisions. The complaint is logged in December. An authorised investigation concludes in February of the following year that discrimination occurred, and the appeal period ends in March. The group reports the case as a complaint received in the first year but not as a confirmed incident for that year under its documented cut-off rule. It includes the confirmed incident in the following reporting period, explains the population and category, and describes corrective action only after legal and privacy approval. This is an illustrative process, not a universal cut-off rule.

ADAPT TO FACTS / C6. The undertaking has an own-workforce human-rights policy covering forced labour, human trafficking, discrimination and accident prevention. It does not currently include a separate child-labour provision because all direct employees are above the applicable minimum working age; this conclusion is reviewed annually. Employees can raise concerns through a confidential web and telephone channel available in the principal working languages. C7. During the reporting period, one discrimination incident involving the own workforce met the undertaking’s documented confirmation criterion. Corrective action included restoration of the affected employment decision, disciplinary action and review of promotion controls. No confirmed value-chain incidents were identified through the supplier audit, contractual notification and external-alert sources used during the period. These sources do not provide complete visibility across all tiers.

Why it works: the wording identifies the policy scope, mechanism, confirmation basis, population, category, remedy and the limitation of value-chain awareness. It does not identify individuals, present allegations as facts or claim that all risk has been eliminated.

MYTH / REALITY / Myth: “A complaints mechanism proves that the undertaking manages human rights effectively.” Reality: C6 asks whether a mechanism exists. Effectiveness requires separate evidence about accessibility, trust, non-retaliation, response, remedy and outcomes; C7 then asks about confirmed incidents.