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GRI 411: Rights of Indigenous Peoples · 2016
Disclosure GRI 411-1

Incidents of violations involving rights of indigenous peoples

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to report whether it has identified any incidents where the rights of Indigenous peoples were violated, and to describe those incidents in a way that is clear and specific. The focus is on actual violations, not general commitments, policies, or future intentions. If there were no such incidents in the reporting period, that should be stated plainly.

In practice, the main question is how broadly the organisation has looked across its activities and relationships, rather than only at flagship sites or headline projects. The reporting should cover the parts of the business where Indigenous peoples could be affected, including operations and relevant business relationships, so the organisation can show whether any violations were found and where they occurred.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Incident count Count the identified incidents during the reporting period where indigenous peoples’ rights were breached. Use one consistent incident definition and include only cases that meet it in the period being reported. Incident log, grievance records, legal or compliance case files, investigation tracker, and any management summary that reconciles to the final count. Legal / Compliance
Incident status and response For each identified incident, record where it stands now and what action has been taken in response, using the same case list as the incident count. Case management notes, investigation updates, remediation plans, correspondence, and closure records for each incident. Legal / Compliance
+ Show GRI 411-1 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: decide which parts of the business, projects, sites, and time period are in scope for this disclosure, so the count and the follow-up narrative come from the same population.
2Agree what you will treat as an identified incident for this purpose, using a consistent internal rule so only qualifying cases are included in the total.
3Gather the underlying records for each case, such as incident logs, investigation notes, grievance files, legal or community records, and any other source that supports both the count and the case status.
4Compile the figures and the narrative together: report the total number of qualifying incidents for the period, then summarise where each case stands and what action has been taken.
5Record any exclusions, reclassifications, or changes in how cases were counted, and explain them clearly so users can understand how the final number was built.
6Check the draft against the official source and your evidence pack to confirm the scope, count, and status summary are aligned and nothing has been added, omitted, or misstated.
Request the data

Request incident log and case status from Legal / Company Secretariat

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

How many relevant incidents were identified in the period, and what is the current status and follow-up for each one?

Use your organisation’s own case, grievance, incident, complaints, land-access, or stakeholder-engagement terms first, then map them to this disclosure. Keep the request in the language the owner already uses internally, and check the source material before sign-off.

Weak request

Please provide the GRI 411-1 data for the evidence needed for GRI 411:GRI 411-1, including the total number and the status of the incidents and actions taken.

Why it fails: This uses framework language that the owner may not recognise, and it does not tell them which internal log to use, how to count cases, what period to cover, or what fields to return. It is too abstract to produce a clean extract.

Better request

Please pull the [reporting period] extract from your [case log / matter tracker / incident register] for any community rights, land access, consultation, or related matters involving indigenous peoples. For each case, include the reference, date, location, internal category, current status, and action taken, plus a short note on how you counted the cases and any exclusions. Use your team’s own terms, and confirm the source system and approver.

Formal email template
Subject: Data request for [reporting period] case log on indigenous rights-related matters

Hi [name/team],

I’m preparing the sustainability reporting pack and need a pull from your [case log / matter tracker / incident register] for [reporting period]. Please share the records you hold for incidents or disputes linked to indigenous peoples’ rights, using the terms your team normally uses.

For each item, please include the case reference, date opened, location, internal category, current status, and the action taken so far. If you have a count summary already, please include that too, along with any notes on how the count was built and any exclusions.

Please also confirm the source system, the reporting boundary covered, and who can approve the extract. If there are items that should not be included, please note the reason.

This is a training template only; please adapt it to your organisation and check the source material before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send over the [reporting period] extract from your [case log / matter tracker] for any indigenous rights-related incidents or disputes? Please include case ref, date, location, category, status, and action taken, plus the count method and any exclusions. Please use your team’s own terms. Thanks — [preparer name]
Industry examples
Mining / Extractives

Context. A site team keeps a community issues register and a legal team tracks formal disputes.

Adapted request. Please share the [reporting period] extract from the community issues register and any linked legal matter log for incidents or disputes connected to indigenous peoples’ rights. Include case reference, site, date raised, issue type, current status, and actions taken, plus the count method and any exclusions.

Example response. Returned table shows 4 unique cases in the period: 2 resolved, 1 under review, 1 escalated. The owner notes that one reopened matter was counted once because the team’s method treats reopenings as follow-up on the same case.

Infrastructure / Utilities

Context. A project controls team records stakeholder complaints and land-access issues in a project tracker.

Adapted request. Please provide the [reporting period] extract from the project stakeholder tracker for any matters linked to indigenous peoples’ rights. Include project name, case reference, date logged, category, status, and action taken, plus the boundary covered and any items excluded from the count.

Example response. Returned table lists 3 cases across 2 projects: 1 closed after engagement, 1 open pending review, and 1 referred to external counsel. The note explains that only matters within active project boundaries were included.

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

Explain how you defined a reportable case, what sources you used to identify it, and how you decided whether it belonged in the period covered.

Context note

Set out what the figures mean in practice by linking the number of cases and their current status to the organisation’s exposure, response effort, and any remaining issues.

Fluctuation statement

If the numbers changed materially, note whether that was driven by more cases being found, different reporting coverage, or faster closure and follow-up of cases already identified.

Content index entry
GRI 411-1 Incidents of violations involving rights of indigenous peoples — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 411-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We checked that the coverage figure only counts incidents we had identified during the period and that the count was built from our incident log, not from estimates or duplicates.An assurer may test whether the count is complete, whether duplicate records were removed, and whether the period cut-off was applied consistently.Incident register or case log; date-stamped source records; reconciliation showing how records were counted; duplicate removal or de-duplication checks; period-end cut-off review; management sign-off on the final count.
We separated the disclosed cases by their current status and recorded the follow-up actions against each one before publication.An assurer may probe whether status labels were applied consistently, whether actions are linked to the right case, and whether closed, open, or pending matters were treated in the same way across the dataset.Case tracker with status fields; action log or remediation tracker; supporting correspondence or meeting notes; status definitions used by the reporting team; review of case-by-case mapping between status and action taken; approval of the final table or narrative.
The reporting boundary used for this disclosure is documented.Coverage exclusions or late scope changes are not evidenced.Boundary memo, entity or site list, and sign-off record.
The source data reconciles to the working file used for reporting.Figures or statements are copied into the disclosure without a traceable source.Source-system export, calculation workbook, and reconciliation note.

Evidence pack to prepare

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps

Mistakes to avoid when collecting the data

No clear owner for the count
The request goes to the wrong team or person, so no one with the incident log confirms the total before reporting starts.
Using framework language instead of local terms
People ask for data in disclosure wording rather than the organisation’s own incident, grievance, or case-management terms, so the source team cannot map the request cleanly.
Scope is left vague
The team does not define which business units, sites, projects, or activities are in scope, so different contributors pull different sets of cases.
Wrong time basis
The count is taken from the wrong reporting window, such as case open date instead of the period in which the incident was identified.
Mixed counting rules
Some teams count every allegation while others count only confirmed cases, so the total is built from different bases and cannot be compared.
Source labels are stripped out
The original case IDs, status tags, and category names are lost during consolidation, making it impossible to trace each figure back to the underlying record.
Cases that should stay separate are merged
Incidents from different sites, projects, or affected groups are rolled into one line item even though they need separate handling in the source data.
Evidence details are not captured
The file holds the number but not the supporting notes, dates, or document references needed to show where the figure came from.
No sign-off trail
The draft total is circulated without a named reviewer or approval record, so nobody can show who checked the source data before it moved forward.

Where judgement is often needed

Set the group boundary before counting
Decide whether to include only entities under current control for the period or also any businesses bought or sold part-way through, and explain the cut-off you used so the count matches the reporting boundary.
Use one rule for what counts as an incident
Where local laws, site rules or community agreements describe the issue differently, apply a single internal test for inclusion and note any country-by-country differences in how cases were classified.
Treat near-boundary communities consistently
If a community is partly within your operating area or affected only indirectly, document the basis for including or excluding the case and keep that approach consistent across locations.
Choose the reporting date for open cases
State whether you count matters identified during the year, matters still open at year-end, or both, and describe the timing basis used for the total and the status update.
Separate confirmed cases from allegations
If some matters are supported by direct evidence and others are still being investigated, explain whether the total covers only confirmed breaches or also unresolved claims, and describe each status clearly.
Use estimates only where records are incomplete
When site records are missing or fragmented, explain any estimate method, identify the source data used, and distinguish estimated figures from directly counted cases.
Round without losing the trail
If the final number is rounded, keep the underlying unrounded count available for audit trail purposes and make sure the published total still reflects the same population.
Protect sensitive details in the narrative
Where naming a place, community or case would create privacy or safety issues, aggregate the description while still showing the number of incidents and the actions taken.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Mining

*Synthetic example for illustration only.* During the year, we recorded **3** matters where our activities were found to have affected Indigenous rights. - **2** were closed out by year-end after remediation, revised site controls, and follow-up with the affected communities. - **1** remained open at period end; we had agreed an action plan, started implementation, and were monitoring completion dates.

This example shows how to report the count of identified matters and then explain where each one stood at the reporting date, together with the main response taken.

Illustrative (synthetic) example — Utilities

*Synthetic example for illustration only.* We identified **2** cases during the reporting period in which our operations were linked to concerns about Indigenous rights. - **1** case was resolved after compensation, updated engagement, and changes to work practices. - **1** case was still being addressed at the end of the period, with agreed corrective steps underway and progress tracked through our community liaison process.

This example demonstrates a simple narrative disclosure that gives the total number of identified cases and then describes the status of each case and the actions taken.

Company reports

How companies report GRI 411-1

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Chailease Holding Company Limited
Banks / Diverse Financials / Insurance · Taiwan · 2024
Open report →
Chailease Holding Company Limited’s 2024 Sustainability Report provides specific data on incidents related to indigenous peoples’ rights, reporting no violations on pages 147 and 150. The report also addresses incidents of discrimination and corrective actions taken, referencing forced or compulsory labour and human rights on page 147, with further details on employee-related incidents on page 149. However, the report does not clearly detail the outcomes or specific corrective measures taken, nor does it provide comprehensive information on supplier social assessments beyond noting new suppliers on page 150.
SQM / Sociedad Química y Minera de Chile
Mining — Rare Minerals / Precious Metals / Gems · Chile · 2024
Open report →
SQM's Sustainability Report 2024 states there were no violations involving the rights of Indigenous peoples during the reporting period (p.362). The report also provides information on incidents of corruption and legal actions taken (p.364). However, details on incidents related to child labor and health and safety impacts are mentioned but not clearly quantified or elaborated in the provided excerpts, leaving some aspects unclear.
Zydus Wellness Limited
Food Production — Agricultural · India · 2025
Open report →
Zydus Wellness Limited’s Integrated Annual Report 2024-25 provides a numeric value for incidents involving the rights of indigenous peoples on page 52, indicating some level of disclosure on this topic. The report also includes narrative information related to actions taken on manufactured capital and customer health and safety, referencing GRI standards on the same page. However, details on the nature or outcomes of these incidents, as well as comprehensive coverage of related policies or mitigation measures, are not clearly presented in the evidence provided.
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Scenarios to work through

During the year, a project team logged two separate complaints from an indigenous community about access to a traditional area near a worksite. One complaint was resolved through agreed site changes; the other was still being reviewed at year-end.

QHow should the preparer decide what to include in the disclosure, and what supporting detail should be gathered for each case?
Reveal model answer →

A contractor’s security staff blocked community members from entering a customary gathering area, but the issue was corrected the same day and the contractor apologised. Management is unsure whether a short-lived event still belongs in the year-end disclosure.

QShould this event be included, and if so, how should it be treated in the narrative?
Reveal model answer →

The legal team has one substantiated case from a prior year that is still under remedy, and one new complaint raised this year that was found to be unrelated to indigenous rights. The reporting team is unsure whether both should appear in the current-year disclosure.

QWhich matters belong in the current-year disclosure, and how should the preparer separate them?
Reveal model answer →

At year-end, there were three identified incidents involving indigenous rights: one was closed with compensation paid, one was still being negotiated, and one had been referred to an external body for review. The draft report currently lists only the number.

QWhat additional information should the preparer add so the disclosure is complete enough for readers?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 411-1
within GRI 411: Rights of Indigenous Peoples
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

For GRI 411-1 Rights of Indigenous Peoples, what incident data do I need to gather before drafting the disclosure?+
How should I set the scope for a GRI 411-1 Rights of Indigenous Peoples disclosure using this page?+
Who should own the GRI 411-1 Rights of Indigenous Peoples data collection in practice?+
What evidence do I need to build an assurance-ready pack for GRI 411-1 Rights of Indigenous Peoples?+
What are the four assurance claims on the GRI 411-1 Rights of Indigenous Peoples page and how do I use them?+
What are the common mistakes to avoid when reporting GRI 411-1 Rights of Indigenous Peoples?+
How do I turn the GRI 411-1 Rights of Indigenous Peoples data into a draft disclosure?+
Can I use the synthetic example on the GRI 411-1 Rights of Indigenous Peoples page as a template for my own disclosure?+
What does the downloadable Prep & Assurance workbook do for GRI 411-1 Rights of Indigenous Peoples?+
How should I use the printable Library Card PDF for GRI 411-1 Rights of Indigenous Peoples?+
Where can I find real published company examples for GRI 411-1 Rights of Indigenous Peoples?+
More questions this page can help with
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